ML19199A597
| ML19199A597 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/18/1975 |
| From: | Blake E METROPOLITAN EDISON CO. |
| To: | |
| References | |
| NUDOCS 7905040310 | |
| Download: ML19199A597 (7) | |
Text
_
l 2'.
,(
6 S
IOiLWF.D COR11SPO.YDtyy
- UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION t
Before the Atomic Safety and Licensing Board In the Matter of
)
)
MET.ROPOLITAN EDISON COMPANY, ET AL.
)
)
Docket No. 50-320 (Three Mile Island Nuclear
)
)
Station, Unit 2)
)
APPLICANTS' INTERROGATORIES TO INTERVENORS FREDERICK AND GERTRUDE HELLRICH, ET AL.,
SET I.
- 1. ',These interrogatories are filed pursuant to 10
. C.F.,R. 52.740b.
Applicants request that the interrogatories
.in Athachment A be answered fully, in writing and under oath, 8
by those individuals among Intervenors, who have personal knowledgethiereoforaretheclosesttoha'vingpersonalknow ledge thereof.
If the interrogatories are answered by more than one perscn, whether or not he verifies the answers such person's name and relationship to Intervenors should be set forth together with an identification of which interrogatori es, or portions thereof, he is responsible for answering.
2.
Each interrogatory is instructed to be answered i
in four parts in accordance with the following. format:
Interrocatorv No.
I-
[ Restate Interrogatory]
C' p
/ r'A N
//
oeerr,,o S\\
l U$k C y
i g.
79050403\\f b
p3 0F AUG 21 :375 > r :
.g
'i
,f,-
e.,~._... :
- c..
,.]
") ~
\\i ^L-
'q,13 p.7'- ^
P
.a 1
. (~,.
p.
Answer _,to Interrocatorv No.
I-a)-
Provide the direct detailed answer to the, interrogatory.
b)' Provide the basis for the answer, including identification by title, author and date of all studies, reports, or other dccuments, or specified parts thereof, relied upon by Intervenors for the answer.
c)
Identify the witness (es), if any, whom Intervenors intend to have testify on the subject matter questioned and include'the expert qualifications, if applicable, for such witness (es).
8 d)
Identify the exhibits, if any, which Inter-venors intend to introduce into evidence at the hearing on the subject matter questioned.
3.
All references to contentions in Applicants' Inter-rogatories are to subparagraphs (a) through (h) and the preamble thereto of Paragraph "4.
Contention," set out in Intervenors' Petition for Leave to Intervene, filed on August 14, 1974, and corrected at the prehearing conference on.May 22, 1975.
Respectfully submitted,
- SHAW, TTMAN, DOTTc & TROWDRIDGE jfl
/$ Y m
y rge/F. 4'rowoticge
[
C6unsel for Applicant 9
q~
i s.
a
~
~
-(}
ATTACHMENT A I-1.
In 'the preamble to 'Intervenors '
contention, Inteivenors refer to "The proposed transmission line."
Does this term, as modified by the language "with respect to that Sector in Berks County" mean the approximately 7-mile segment of 500KV transmission line which has already l
been constructed and which runs.between the abandoned Bechtelsville substation site and Met Ed's Hosensack substation?
If not, define " proposed transmission line" a'nd what ir meant by "that Sector in Berks County" in this context.
I-2.
In subparts (a), (b), (c), (d),
(. e), (f), (g) and (h) l of Intervenors' contention, Intervenors variously refer to "the proposed line" and in 'ne instance to "the une s
o in question."
By use of the phrase "the proposed line" or "one in question," do Intervenors mean in each instance the approximately 7-mile segment of 500KV trans-mission line which runs between the abandoned Bechtels-ville substation site and Met Ed's Hosensack substation?
If not, define what is meant by "the proposed line" or "one in question" in each instance where it is used throughout Intervenors' contention.
I-3.
In subparts (a), (c) and (d) of Intervenors' contention, Intervenors refer variously to " service area," " area of service" and " area."
In each instance, does the term 8
\\l J
t.
g h
tY
. -2 Q
D L
~
? service area," " area of service" or " area" includ e the service areas of each of, the three Applicants in thi s
proceeding?
If not, state which of Applicants' service areas is included and explain why the service area fo r
any of the three Applicants should not be included for considerati an in this proceeding.
I-4.
In subpart (a) of Intervenors' contention, f
Intervenors allege that
" Applicant can supply the electrical services within its service area without the proposed line" Explain in detail how Intervendrs propose th at Applicants supply electrica'l service in their service areas with the proposed line.
out I-5.
In subpart (b) of Intervenors' contention, Intervenors refer to " alternate routes."
Provide specific identifi-cation of the " alternative routes" referred to in thi instance and 'or each of the identified route s
f s detail the effect of that route selection on each of th
" cost /
e benefits" factors.
I-6.
In subpart (b)' of Intervenors ' contention, Intervenors refer to " environmental impacts."
Identify each of the
" environmental impacts" to which Irterv enors refer.
I-7.
In subpart (c) of Intervenors' contention, Intervenors 1
I refer to the " projected growth in the population 5
~b l
.q
\\o
c.
[LLk
()
^
~ )
t Provide Intervenors' estimate of the arithmetic effect
\\
v-of halving and oubling such " projected growth in the
\\G population," on the projected " compound load growth rate" y;
to which Intervenors refer in subpart L
(d) of Intervenors' h
contention.
I-8.
With respect to subpart (d) of Intervenors' contention, describe in detail all the " land use patterns" which Intervenors have taken into consideration in the compu-tation of a " compound load growth rate of 2 to 4 percent in the area of scrvice."
I-9.
With respect to subpart (d) of Intervenors' contention, describe in detail the " economic conditions" which s
Intervenors have considered in calculating a " compound load growth rate of 2 to 4 percent in the area of service "
i I-10.
In subpart (d) of Intervenors' contention, Intervenors refer to " future proposed lines, other than the one in question."
Provide a detailed list of the future lines which have been proposed and to which Intervenors refer.
1-11.
In subpart (e) of Intervenors '
contention, Intervenors contend that "The requirements of the PJM Power Pcol can be adequately served withoct the proposed line."
Is it Intervenors' contention that the requirements can be met if the proposed line is simply eliminated or k
4 i
'f
\\r
<1
.I.
4 e
O
-)
{
do Intervenors contend that the-requirements can be met with a line at a different location?
In either case, provide a detailed analysis which supports Intervenors' i
statement.
I f
I-12.
In subpart (g) of Intervenors' contention, Intervenors refer to "taking away needed agricultural lands."
Describe in detail the "needed agricultural lands" which 4
)
Intervenors contend the " proposed line" will take away.
Include in such description Intervenors' 3
estimate of the acreage of crops which will be lost annually as a result of "the proposed line."
l 1
I-13.
In subpart (g) of Inrervenors' contention,.Intervenors 8
refer to "taking.away.
.. woodlands."
Describe in detail Intervenors' view of the amount and types of
" woodlands" which have been taken away by construction of "the proposed line."
I-14.
In subpart (g) of Intervenors' contention, Intervenors refer to " adverse esthetic effects."
Taking into account that the Bechtelsville Hosensack segment of the 500KV line has been constructed following the common corridor concept and that parallel positioning of towers has been i
employed, describe in detail the " adverse esthetic effects" to which reference is made, limi-ing your response to
~
addressing the appro::imately seven-mile segment between
?
t 0
4 q0
-l r
U
b i
~
t
() '
)
Bechtelsville and Hosensack.
I-15.
With respect to subpart (h) of Intervenors' contention explain Intervenors' allegation that "the impact of e
the proposed line will adversely affect the land use, directly and indirectly."
Include in your response
' icentification of the " land use" to which referen is made and precisely how 'the proposed line "will ad-versely affect" such " land use, directly and indirectly "
1-16.
In subpart (h) reference is made to " costs relating to the loss of productivity."
Provide a detailed descrip-tion of the " costs relating to the loss of producti A
vity" which Intervenors contend are ' associated with "the proposed line."
I-17.
In subpart (h) of Intervenors' contention, Intervanors re. r to adverse effects on " values of land."
I Identify the land to which-Intervenora refer. E:: plain and quantify the adverse effect on the values of such land and provide the basis for such.quantification I-18.
In subpart (h) of Intervenors' contention, Intervenors refer to " loss of natural resources."
Provide a detailed description of the " natural resources" to which Intervenors
- refer, and provide for each such natural resource, t
the precise loss which Intervenors attribute to "the propo sed line."
lr t.
(m
~Q X
ust 18, 1975 UNITED STATES OF AMERICA NUCLEAR REGULATORY COM1ISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
HETROPOLITA'I EDISON COMPANY, )
)
Docket No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Interrog-atories to Intervenors Frederick and Gertrude Hellrich, et al.
Set I," dated August 18, 1975, were served upon those persons on the attached Service List, by deposit in the United States mail, postage prepaid, this 18th day ~.of August, 1975.
a 0
W /YS),
Ernest L.
Blake, Jr.
I 2
. t,,
a '. Q-
[
q.
e
,Q 8
-3
- a v/
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY,
)
)
Docket No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
SERVICE LIST Edward Luton, Esquire Chairman Henry J. McGurren, Esquire Atomic Safety and Licensing Board Office of the Executive Legal Director U.S. Nuclear Regulatory Commission.
U.S. Nuclear Regulatory Washington, D.C.
2G555 Commission Washing ~ ton, D.C.
20555 Mr. Gustave A.
Linenberger Atomic Safety and Licensing Board Karin W.
Carter, Assistant U.S. Nuclear Regulatory Commission Attorney General Washington, D.C.
20555 Office of Environment Dr. Ernest O.
Salo Department of Environmental Resources Professor, Fisheries Research Instituta, EH-10 709 Health and Welfare Building College of Fisheries Harrisburg, Pennsylvania 17120 University of Washington Seattle, Washington 98195 Atomic Safety and Licensing Board Panel U.S.
Mr. Chauncey R.
Kepford Nuclear Regulatory Commission Citizens for a Safe Environment 108-N. Pershing Avenue Washington, D.C.
20555 York, Pennsylvania 17403 Atomic Safety and Licensing Appeal Board Lawrence Sager, Esquire U.S.
Sager & Sager Associates Nuclear Regulatory 45 High Street Commission Washington, D.C.
20555 Pottstown, Pennsylvania 19464 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l1 t.
.