ML19220A491
| ML19220A491 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/11/1973 |
| From: | Blake E, Silberg J SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 7904230023 | |
| Download: ML19220A491 (9) | |
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October 11,1973 UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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METROPOLITAN EDISCN COMPANY,
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Docket No. 50-320 et al.
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(Three Mile Island Nuclear
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S tation, Unit 2)
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APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF COCUMENTS TO CITIZENS FOR A SAFE ENVIRONMENT AND ENVIRONMENTAL COALITION ON NUCLEAR POWER Pursuant to Section 2.740b of the Commission's Rules of Practice, Metropolitan Edison Company, Jersey Central Power and Light Company and Pennsylvania Power and Light Company (Applicants) hereby request that Citizens for a Safe Environment and Environmental Coalition on Nuclear t
Power (Intervenors) answer separately and fully in writing, under oath and in accordance with the provisions of Section 2.740b, the written interrogatories set forth in Section I below.
Applicants also request that Intervenors provide the documents identified in Section II below in accordance
,with Section 2.741 of the' Commission's Rules of Practice.
.The numbering of the contentions is that used in Intervenors '
July 19, 1973 " Revised Objections".
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INTERRCGATORIES A.
Contention 1 1.
With respect to the " alternative proposals whereby large tracts of 1 Lad will not be transversed and severed":
a.
Describe in detail each "large tract of land" which will be "transversed and severed" by Applicants' proposed route for the TMI-Juniata transmission line.
State the exact location and size of each such tract, its present use, and the nature of its existing vegetation (i.e. woodlots, pasture, cultivated fields, etc.).
b.
Describe in detail how Applicants ' proposed route for the TMI-Juniata transmission line would affect the use of these "large tracts".
If "the alternative proposals whereby large c.
tracts of land will not be transversed and severed" involve alternate routes, describe in detail each such route and provide the exact location and size of each tract of land transversed by such route, the present use of each such tract, the nature of its existing vegetation (i.e. woodlots, pasture, cultivated fields, etc.), and any homes or businesses which are either located on each such tract or which would be affected by such route.
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mns4 d.
Describe in detail how each alternate route described in c. above would affect the use of the tracts of land which it transversed and state the basis for your answer.
e.
If the " alternate proposals whereby large tracts of land will not be transversed and severed" involve alternatives other than alternate routes, describe in detail each such alternative.
2.
With respect to the allegation that " towers could be placed in such a manner as to avoid disruption of cultivation and agricultural use":
Describe in detail how the towers for Applicants' a.
proposed route of the TMI-Juniata transmission line will be placed.
b.
State the nature and monetary value of the cultivation and agricultural use which would be disrupted and provide the basis for your answer.
c.
Describe in detail the nature and extent of the disruption of cultivation and agricultural use which would result from the towers as presently planned.
d.
Describe in detail how the towers for the TMI-Juniat'a transmission line could be placed so as to avoid disruption of cultivation and Gb-130 _
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If this placement involves a different route, describe such route in detail and state the type of cultivation and agricultural use of the land transversed by such different route.
3.
With respect to the allegation that "the lines and towers could be placed so that woodlots are not destroyed":
a.
State the location of each woodlot which you allege would be destroyed, and the number of acres of such woodlot which would allegedly be destroyed.
b.
State whether any of the woodlots which allegedly would be destroyed are virgin growth.
c.
Identify the type of trees which you claim would be destroyed for each woodlot identified in a.
above.
d.
Specify any unusual characteristics of the woodlots which allegedly would be destroyed and explain the nature of these characteristics.
e.
Describe in detail the method by which "the lines and towdra could be placed so that wood-lots are not destroyed".
f.
If the method described in e.
above involves alternative routes, describe in detail each such route, specifying the agricultural use of each tract traversed by the route, acreage (15~131
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O of woodlots which would be cleared, and homes or businesses which would be affected.
4.
Identify each document upon which this contention is based.
5.
Identify by name and address each individual who has provided you with information relating to this contention and describe in detail such information.
6.
Identify by name and address each individual whom you intend to call as a witness with respect to this contention and state the educational and professional qualifications of each such individual.
B.
Contention 3 7.
With respect to the allegation that "the towers could be placed in such a manner as to lessen the adverse asthetic effect of the towers":
a.
Describe in detail the adverse asthetic effects of the placement of the towers as presently proposed, specifically identifying the location and direction of each vista from which the adverse asthetic affect could be observed.
b.
Describe in detail the method of tower place-ment which you allege would lessen the adverse asthetic effects of the towers.
8.
With respect to the allegation that " towers could be placed away from the highway in such an area as not to gy132
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hinder future development of the properties on which the towers are sited":
a.
Specifically identify the location of each property "on which the towers Are [to be]
sited" whose future development would be hindered as a result.
b.
Describe in detail the character of the
" future development" which would be hindered by the presently proposed tower placement and specifically identify each location at which each type of development would be hindered.
c.
For each type of " future development" which would be hindered, describe in detail the availability of other locations in York and Dauphin Counties for such types of development.
d.
Describe in detail each method by which " towers could be placed away from the highway in such an area as not to hinder future development of the properties on which the towers are sited".
e.
With respect to each method described in d.
above, identify the location of each tower and the existing development of the property on which each tower would be located.
9.
Identity each document upon which this contention is based.
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10.
Identify by name and address each individual who has provided you with information relating to this contention and describe in detail such information.
11.
Identify by name and address each individual whom you intend to call as a witness with respect to this contention and state the educational and professional qualifications of each such individual.
II.
REQUEST FOR PRODUCTION OF DOCUMENTS 12.
Applicants request that Intervenors produce for Applicants' use, or produce and permit Applicants to inspect and copy, at a specific time and place and in a manner to be agreed upon, all of the documents identifie'd or referenced in Section I above.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Dy:
70 M,N, Jay E.
Silberg Ernest L.
Blake, Jr.
Counsel for Applicants Dated:
October 11, 1973
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October
,1, 1973 UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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METROPOLITAN EDISON COMPANY,
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JERSEY CENTRAL POWER & LIGHT
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Docket No. 50-320 COMPANY and PENNSYLVANIA
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ELECTRIC COMPANY
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(Three Mile Island Nuclear
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Station, Unit 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Interrogatories and Request for Production of Documents to Citizens for a Safe Environment and Environmental Coalition on Nuclear Power" were served on the following by deposit in the United States mail, first class or airmail, this lith day of October, 1973:
Charles A. Haskins, Esq.
Dr.
M.
Stanley Livingston Chairman 1005 Ca]le Largo Atomic Safety and Licensing Sante Fe, New Mexico 87501 Board Windy Hill Farm Joseph Gallo, Esq.
Bluemont, Virginia 22012 Office of General Counsel U.S. Atomic Energy Commis!; ion Dr. John R.
Lyman Washington, D.C.
20545 Department of Environmental Sciences & Engineering Lawrence Sager, Esq.
University of North Carolina 45 High Street Chapel Hill, North Carolina Pottstown, Pennsylvania 17105 27514 Gb-135
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Frank.R. Clokey Special Assistant Attorney General Room 219 Town House Apartments Harrisburg, Pennsylvania 17105 Office of the Secretary U.S. Atomic Energy Commission Washington, D.C.
20545 Attn:
Chief, Public Proceedings Branch JWff bA4 Q,
3 Ernest L.
Blake, Jr.
Counsel for Applicants Gb' LUG
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