ML19276F809
| ML19276F809 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 03/16/1979 |
| From: | Mcgarry J DUKE POWER CO. |
| To: | |
| References | |
| NUDOCS 7904120286 | |
| Download: ML19276F809 (30) | |
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NUCLEAR REGULATORY COMMISSION A
'A In the Matter of
)
)
DUKE POWER COMPANY
)
)
Docket No. 70-2623 (Amendment to Materials
)
License SNM-1773 for Oconee
)
Nuclear Station Spent Fuel
)
Transportation and Storage
)
at McGuire Nuclear Station)
)
APPLICANT'S INTERROGATORIES TO SAFE ENERGY ALLIANCE (SEA) AND REQUESTS TO PRODUCE Pursuant to the Licensing Board's Order of February 23, 1979 and 10 CFR SS2.740b and 2.741, Applicant serves the following interrogatories and requests to produce on SEA to be answered under oath or affirmation.
Each answer snould include all pertinent knowledge in the possession of all officers, directors, or members of your organization as well as pertinent information possessed by any advisor, agent, employee or counsel.
In answering the interrogatories and in responding to the request to produce, please recite the interrogatories or request preceding each answer.
These interrogatories and this request to produce shall be continuing, and, if after answering or responding, additional information or documents are obtained which render prior responses incorrect or no longer true, please update the answer and response with such additional information.
The term " document" shall include, without limitation, writings, drawings, graphs, charts, 790M2M %
photographs or other data known to or in your possession, custody or control.
In the event any document requested in these interrogatories has been destroyed or is unavail-able, describe in detail-the reasons therefore.
Interrogatories and Requests to Produce 1.
Have you reviewed Applicant's March 9, 1978 Applica-tion for License to Store Oconee Nuclear Station Fuel at McGuire Nuclear Station?
If not, why not?
If so, please answer the following:
a.
Do you object to any of the material contained therdin?
- b. ~ Are any facts contained therein erroneously stated?
c.
Has any pertinent information been omitted?
d.
Is there any error in the methodology employed?
e.
If the answer is affirmative to items a - d above, please state with specificity, making reference to the particular section or subsection as the case may be, that material with which you take issue and the reason why you take issue.
f.
Please set forth the material upon which you rely as supporting your objection, including any analysis you have performed or caused to be performed in this regard.
- 2.
Have you reviewed Applicant's responses to NRC Staff's questions concerning its subject Application?
If not, why not?
If so, please answer the following:
a.
Do you object to any of the material contained therein?
b.
Are any facts contained therein erroneously stated?
c.
Has any pertinent information been omitted?
d.
Is there any error in the methodology employed?
e.
If the answer is affirmative to items a - d above, please state with specificity that material with which you take issue and the reason why you take issue.
f.
Please set forth the material upon which you rely as supporting your objection, including any analysis you have performed or caused to be performed in this rega ".
3.
Have you reviewed the NRC Staff's Environmental Impact Appraisal issued in this case in December 1978?
If not, why not?
If so, please answer the following:
a.
Do you object to any of the material contained therein?
b.
Are any facts contained therein erroneously stated?
c.
Has any pertinent information been omitted?
d.
Is there any error in the methodology employed?
e.
If the answer is affirmative to items a - d above, please state with specificity, making reference to the particular section or subsection as the case may be, that material with which you take issue and the reason why you take issue.
f.
Please set forth the material upon which you rely as supporting your objection, including any analysis you have performed or caused to be performcd in this regard.
4.
Have you -reviewed the NRC Staf f's Safety Evaluation Report issued in this case in January 1979?
If not, why not?
If so, please answer the following:
a.
Do you object to any of the material contained therein?
b.
Are any facts contained therein erroneously stated?
c.
Has any pertinent information been omitted?
d.
Is there any error in the methodology employed?
e.
If the answer is affirmative to items a - d above, please state with specificity, making reference to the particular section or subsection as the case may be, that material with which you take issue and the reason why you take issue.
f.
Please set forth the material upon which you rely as supporting your objection, including any analysis you have performed or caused to be performed in this regard.
5.
Have you reviewed the NRC Staff's Errata of February 13, 1979?
If not, why not?
If so, please answer the following:
a.
Do you object to any of the material contained therein?
b.
Are any facts contained therein erroneously stated?
c.
Has any pertinent information been omitted?
d.
If the answer is affirmative to items a - c above please state with specificity that material with which you take issue and the reason why you take issue.
e.
Please set forth the material upon which you rely as supporting your objection, including any analysis you have performed or caused to be performed in this regard.
6.
Please state whether you are aware of the positions taken by other intervening participants in response to these interrogatories.
7.
Please list the dates of meetings between respective intervening participants regarding the issues presently under consider: tion.
8.
Which, if any, of the respective intervening partici-pants assisted in preparation of the response to these interogatories?
Please list specific names.
9.
Please list individuals who assisted in the prepara-tion of the response to these interrogatories.
Contention 1 Contention 1 reads as follows:
Intervenors contend that shipment of Oconee spent fuel to McGuire for storage is unaccept-able as compared to other alternatives:
(a) Modification of the existing Oconee spent fuel pools to provide additional storage capacity; (b) Construction of a new and separate spent fuel storage facility at the Oconee site; (c) Construction of a new and separate spent fuel storage facility away from the Oconee Site, but other than McGuire.
10.
How"'should cost be considered in determining which, if any, of the alternatives set forth in Contention 1 are superior to Applicant's proposal?
11.
What should Applicant's course of action be in the event that these alternatives could not be utilized until some time after the present Oconee spent fuel storage capability had been completely used?
What is the basis for your position?
Please provide supporting analyses.
12.
What do you consider to be the relevant criteria used to evaluate the proposed alternative in rela-tion to other alternatives?
13.
What is your basis (legal and/or other) for using these criteria?
14.
List in other of importance the criteria specified above.
_7-15.
Have you compared the various alternatives listed in Contention 1 using the criteria specified above?
If so, please provide copies of the analysis.
If not, please explain'.
16.
What is your understanding of the appropriate standard used to reject the proposed alternative when compared to another alternative?
Describe the nature and ex-tent of this standard in detail.
17.
What is your basis (legal and/or other) for the standard specified above?
18.
Have you, compared the various alternatives listed in.,C.ontention 1 using this standard?
If so, please provide copies of this analysis. If not, please explain.
Contention 1(a):
19.
Please set forth in your own words the meaning of Contention 1(a).
20.
What is the supporting basis for Contention 1(a)?
Please list all documents relied upon.
21.
Have you undertaken any research and/or conducted any studies with regard to Contention 1(a)?
If so, please describe the nature of such research and/or studies and provide specific reference to and copies of documents relied upon in such research and/or studies.
22.
Have you contacted any individual and/or group with regard to Contention 1(a)?
If so, please identify
_g_
and indicate the reason for contacting any named in-dividual and/or group, the date of the contact, and the individual and/or group response.
23.
With. respect to ind-ividual and/or groups which you may have contacted with regard to Contention 1(a),
have they prepared any documents, undertaken any research and/or conducted any studies upon which you will rely?
If so, please describe and provide copies.
24.
Do you plan to participate in the upcoming hearing with regard to Contention 1(a)?
If so, please set forth thb substance of your participation.
25.
Do you plan to file testimony in the upcoming hearing with regard to Contention 1(a)?
If so, who will be the sponsor (i.e., witness) of such testimony?
26.
Please identify any witness whom you plan to call at the upcoming hearing with regard to Contention 1(a) and provide a summary of his or her educational and professional background.
Also, please set forth any other information bearing upon his or her quali-fications to testify in thic proceeding in this regard.
27.
If you plan to call any witness at the upcoming hearing with regard to Contention 1(a), please indicate with specificity the nature of his or her testimony.
In addition, please list and pro-vide copies of documents which any such witness will
_9_
rely upon with respect to his or her testimony.
Also, please state whether any such witness has undertaken any research, conducted any studies and/
or contacted any individuals and/or groups with refe'rence to his or her testimony.
If so, please describe and provide copies.
28.
Do you contend that the spent fuel pool for Oconee Units 1 and 2 can be modified?
If so, please des-cribe the specific nature of the modification.
29.
What are the costs associated with the modifica-tion?
30.
What will be the resulting number of spaces?
31.
Wh at length of time is necessary to complete the project?
32.
Do you contend that the spent fuel pool for Oconee Unit 3 can be modified?
If so, please describe the specific nature of the modification.
33.
What are the costs associated with the modifica-tion?
34.
What will be the resulting number of spaces?
35.
What length of time is necessary to complete the project?
36.
Are you aware that Duke has sought permission to modify the configuration of the storage racks in the Oconee Unit 1 and 2 spent fuel pool?
If so, will such modification satisfy your concern with
_lo_
respect to the alternative set forth in Contention 1(a)?
If not, explain with specificity.
Contention 1(b) 37.
Please set forth in your own words the meaning of Contention 1(b).
38.
What is the supporting basis for Contention 1(b)?
Please list all documents relied upon.
39.
Have you undertaken any research and/or conducted any studies with regard to Contention 1(b)?
If so, please describe the nature of such research and/or studies and provide specific reference to and ccpies of documents relied upon in such research and/or studies.
40.
Have you contacted any individual and/or group with regard to Contention 1(b)?
If so, please identify and indicate the reason for contacting any named in-dividual and/or group, the date of the contact, and the individual and/or group response.
41.
With respect to individual and/or groups which you may have contacted with regard to Contention 1(b),
have they prepared any documents, undertaken any research and/or conducted any studies upon which you will rely?
If so, please describe and provide copies.
. 42.
Do you plan to participate in the upcoming hearing with regard to Contention 1(b)?
If so, please set forth the substance of your participation.
43.
Do you plan to file testimony in the upcoming hearing with regard to Contention 1(b)?
If so, who will be the sponsor (i.e., witness) of such testimony?
44.
Please identify any witness whom you plan to call at the upcoming hearing with regard to Contention 1(b) and provide a summary of his or her educational and professional background.
Also, please set forth any other information bearing upon his or her quali-fications to testify in this proceeding in this regard.
45.
If you plan to call any witness at the upcoming hearing with regard to Contention 1(b), please indicate with specificity the nature of his or her testimony.
In addition, please list and pro-vide copies of documents which any such witness will rely upon with respect to his or her testimony.
Also, please state whether any such witness has undertaken any research, conducted any studies and/
or contacted any individuals and/or groups with reference to his or her testimony.
If so, please describe and provide copies.
46.
Where would the independent storage facility be located on the Oconee Site?
47.
How much would this facility cost?
48.
What is the environmental impact associated with the con-struction and operation of such a facility?
49.
Will the spent fuel produced at any of the Oconee units need to be packaged and shipped to this separate spent fuel facility?
50.
When would this facility be able to receive spent fuel?
51.
How many spent fuel assemblies could be stored under this alternative?
52.
What are the doses to the workers and the general pu61'ic associated with this spent fuel storage activity?
53.
If a federally approved of f-site disposal area could be available by the end of 1983, should Applicant now construct the on-site facilities suggested by this contention?
If so, what is the basis for your response.
Contention 1(c) 54.
Please set forth in your own words the meaning of Contention 1(c).
55.
What is the supporting basis for Contention 1(c)?
Please list all documents relied upon.
56.
Have you undertaken any research and/or conducted any studies with regard to Contention 1(c)?
If so, please describe the nature of such research and/or studies and provide specific reference to and copies of documents relied upon in such research and/or studies.
57.
Have you contacted any individual and/or group with rega'rd to Contention 1(c)?
If so, please identify and indicate the reason for contacting any named in-dividual and/or group, the date of the contact, and the individual and/or group response.
58.
With respect to individual and/or groups which you may have contacted with regard to Contention 1(c),
have they prepared any documents, undertaken any research.and/or conducted any studies upon which you.will rely?
If so, please describe and provide copies.
59.
Do you plan to participate in the upcoming hearing with regard to Contention 1(c)?
If so, please set forth the substance of your participation.
60.
Do you plan to file testimony in the upcoming hearing with regard to Contention 1(c)?
If so, who will be the sponsor (i.e.,
witness) of such testimony?
61.
Please identify any witness whom you plan to call at the upcoming hearing with regard to Contention 1(c) and provide a summary of his or her educational and professional background.
Also, please set forth any other information bearing upon his or her quali-fications to testify in this proceeding in this regard.
-14_
62.
If you plan to call any witness at the upcoming hearing with regard to Contention 1(c), please indicate with specificity the nature of his or her testimony.
In addition, please list and pro-vide copies of documents which any such witriess will rely upon with respect to his or her testimony.
Also, please state whether any such witness has undertaken any research, conducted any studies and/
or contacted any individuals and/or groups with reference to his or her testimony.
If so, please describe and provide copies.
63.
How woulb this situation differ from the one cur-rently objected to?
64.
Where would this independent storage facility be located?
65.
How much would the facility cost?
What is the basis for your answer?
66.
Will the spent fuel produced at any of the Oconee units need to be packaged and shipped to this separate spent fuel facility?
67.
When would this facility be able to receive spent fuel?
Have you considered the number of permits necessary and the length of time required to ob-tain them?
Please explain.
68.
What is the environmental impacted associated with the construction ind operation of such a facility?
What is the basis for your answer?
i 69.
How many spent fuel assemblies could be stored under this alternative?
What is the basis for your answer?
70.
What are the doses to the workers and the general publ.ic associated with this spent fuel storage activity?
What is the basis for your answer?
Contention 2 Contention 2 reads as follows:
Intervenors contend that transportation of spent nuclear fuel from the Oconee Nuclear Station for storage at the McGuire Nuclear Station will create an unacceptable hazard by significantly increasing the radiation doses to persons in the region near the proposed transportation routes between the two facilities.
Specifically:
(a)
The're will be an unacceptable incremental burden of radiation dose to persons living
~'
in the vicinity of the transportation routes.
(b)
There will be an unacceptable incremental burden of radiation dose to persons travel-ing over the transportation routes concurrently with spent fuel shipment.
(c)
There is likely to be an unacceptable incre-mental burden of radiation dose to persons in the vicinity due to an accident or delay in transit.
71.
Please describe completely all assumptions regarding the transport of spent fuel including:
(i) amount per shipment (ii) manner of shipping and type of shipmen't con-tainer (iii) amount of radiation emitted by said containers in terms of alpha, beta, gamma, X-ray, and other classes o
(iv) expected number of accidents per 1000 shipments.
72.
What do you consider to be the relevant criteria used to determine if shipment of spent fuel creates an unacceptable radiation hazard?
73.
What is basis (legal or other) you rely upon for the criteria specified above?
74.
Have you analyzed the proposed alternative in light of the criteria specified above?
If so, provide copies of this analysis.
If not, please explain.
75.
What increase in radiation doses do you consider to be acheptable?
In answering, please specify, wiEh supporting basis, the acceptable dose for:
(a) one individual from one spent fuel shipment; (b) the total population of persons in the region near the proposed transp( rtation routes from one spent fuel shipment; (c) one individual from all spent fuel shipments contemplated under this Application, and (d) the total population of persons in the region near the proposed transportation routes from all spent fuel shipments comtemplated under this Application.
76.
Have you read 49 CFR Part 170-189?
If not, why not?
If so, please answer the following:
(a)
Do you agree with the dose rate limits for transport of spent fuel contained in 49 CFR
.Part 170-189 in general and 49 CFR S173.393 (j) specifically?
If not, what should these limits be?
Please provide all supporting analyses, calcu-lations and documentation.
(b)' Do you agree that pursuant to the aforementioned regulations the public may be subjected to a small increase in radiation dose during the transport of spent fuel?
Do you consider this increase an acceptable radiation hazard?
If so, upon what do you base contention 2(a) and (b)?
If not, please explain 77.
Have you read Table S-4 to 10 CFR 551.20(g)?
If not, why no-t?
If so, please answer the following:
(a)
Do you agree with the doses set forth therein?
If not, what should their limits be?
Please provide all supporting analyses, calculations and documentation.
(b)
Do you agree that pursuant to the aforementioned regulations the public may be subjected to a small increase in radiation dose during the transport of spent fuel?
Do you consider this increase an acceptable radiation hazard?
If so, upon what do you base contention 2(a) and (b)?
If not, please explain.
78.
Have you read 10 CFR Part 71?
If not, what not, If so, please answer the following:
s (a)
Do you agree with the parameters set forth therein?
If not, what should these limits be?
Please provide all supporting analyses, calculations and documenta-
. tion.
(b)
Do you agree that pursuant to the aforementioned regulations the public may be subjected to a small increase in radiation dose during the transport of spent fuel?
Do you consider this increase an acceptable radiation hazard?
If so, upon what do you base contention 2(a) and (b)?
If not, please explain.
Contention 2('a) 79.
Please set forth in your own words the meaning of Contention 2(a).
80.
What is the supporting basis for Contention 2(a)?
Please list all documents relied upon.
81.
Have you undertaken any research and/or conducted any studies with regard to Contention 2(a)?
If so, please describe the nature of such research and/or studies and provide specific reference to and copies of documents relied upon in such research and/or studies.
82.
Have you contacted any individual and/or group with regard to Contention 2(a)?
If so, please identify and indicate the reason for contacting any named in-dividual and/or group, the date of the contact, and the individual and/or group response.
83.
With respect to individual and/or groups which you may have contacted with regard to Contention 2(a),
have they prepared any documents, undertaken any research and/or conducted any studies upon which you will rely?
If so, please describe and provide copies.
84.
Do you plan to participate in the upcoming hearing with regard to Contention 2(a)?
If so, please set forth the substance of your participation.
85.
Do you plan to file testimony in the upcoming hearing with regard to Contention 2(a)?
If so, who will be thp. sponsor (i.e., witness) of sucn testimony?
86.
Please identify any witness whom you plan to call at the upcoming hearing with regard to Coatention 2(a) and provide a summary of his or her educational and professional backgroerd.
Also, plee:;e set forth any other information bearing upon his or her quali-fications to testify in this proceeding in this regard.
87.
If you plan to call any witness at the upcoming hearing with regard to Contention 2(a), please indicate with specificity the nature of his or her testimony.
In additian, please litt and pro-vide copies of documents which any such witness will rely upon with respect to his or her testimony.
Also, please state whether any such witness has undertaken any research, conducted any studies and/
or contacted any individuals and/or groups with reference to his or her testimony.
If so, please describe and provide copies.
88.
Do you take issue with the doses set forth in NRC Staff documentation?
If so, what is the basis for your objection.
If not, what is the basis for your state-ment that such dose levels are unacceptable?
89.
What is the magnitude of the incremental amount of dose referred to?
What are the annual projected doses?
90.
What is the basis for your dose levels?
91.
What is an acceptable radiation dose to persons living in the vicinity of the transportation routes?
92.
What is your definition of " vicinity" as used in this contention?
93.
What is your definition of "living" as used in this contention?
94.
What transportation routes do you assume?
95.
Please state, and give all sources supporting the following:
(a)
Number of people living within 25 feet of transportation route and the unacceptable incremental burden of radiation dose they will suffer from the passage of 1 shipment of spent fuel.
I
\\
(b)
Same as (a) except 50 feet.
(c)
Same as (a) except 75 feet.
(d)
Same as (a) except 100 feet.
(e)
Same as (a) except 150 feet.
(f)
Same as (a) except 200 feet.
(g)
Same as (a) except 300 feet.
(h)
Same as (a) except 500 feet.
(i)
Same as (a) except 1000 feet.
96.
What is the duration and rate of the exposure used in 'our estimates?
j 97.
Please provide all assumptions used for traffic patterns, demographic distribution, and traffic density with re-spect t location, time of day and accident incidence.
Contention 2(b) 98.
Please set forth in your own words the meaning of Contention 2(b).
99.
What is the supporting basis for Contention 2(b)?
Please list all documents relied upon.
100. Have you undertaken any research and/or conducted any studies with regard to Contention 2(b)?
If so, please describe the nature of such research and/or studies and provide specific reference to and copies of documents relied upon in such research and/or studies.
101. Have you contacted any individual and/or group with regard to Contention 2(b)?
If so, please identify and indicate the reason for contacting any named in-dividual and/or group, the date of the contact, and the individual end/or group response.
102. With respect to individual and/or groups which you may have contacted with regard to Contention 2(b),
have they prepared any documents, undertaken any research and/or conducted any studies upon which you will rely?
If so, please describe and provide copies.
103. Do you plan to participate in the upcoming hearing with regard to Contention 2(b)?
If so, please set forth the substance of your participat. ion.
104. Do you plan to file testimony in the upcoming hearing with regard to Contention 2(b)?
If so, who will be the sponsor (i.e.,
witness) of such testimony?
105. Please identify any witness whom you plan to call at the upcoming hearing with regard to Contention 2(b) and provide a summary of his or her educational and professional background.
Also, please set forth any other information bearing upon his or her quali-fications ta testify in this proceeding in this regard.
106. If you plan to call any witness at the upcoming hearing with regard to Contention 2(b), please indicate with cpecificity the nature of his or her testimony.
In addition, please list and pro-vide copies of documents which any such witness will rely upon with respect to his or her testimony.
Also, please state whether any such witness has undertaken any research, conducted any studies and/
or contacted any individuals and/or groups with reference to his or her testimony.
If so, please describe and provide copies.
107. Do you take issue with the doses set forth in NRC Staff documentation?
If so, w2at is the basis for your objection?
If not, what is the basis for your statement that such dose levels are unacceptable?
108. What is the magnitude of the incremental amount of dose referred to?
What are the annual projected doses? ;
109. What is the basis for your dose levels?
110. What is your definition of " concurrently" as used
. in this contention?
111. What is your definition of " traveling" as used in this contention?
112. What transportation routes do you assume?
113. What is the duration and rate of the exposure used in your estimates, 114. Please state exactly the following:
(a)
All assumptions made for persons traveling concurrently with these shipments including but not limited to:
(i) number of people who will be exposed.
(ii) average exposure time of people and their number:
(a) traveling in same direction; (b) traveling in the opposite direction; (c.) traveling perpendicular to shipment.
(iii) average closest approach to shipment.
115. Please provide all assumptions used for traffic patterns, demographic distribution, and traffic density with respect to location, time of day and accident incidence.
Contention 2(c) 116. Please set forth in your own words the meaning of Contention 2(c).
117. What is'the supporting basis for Contention 2(c)?
Please list all documents relied upon.
118. Have you undertaken any research and/or conducted any studies with regard to Contention 2(c)?
If so, please describe the nature of such research and/or studies and provide specific reference to and copies of documents relied upon in such research and/or studies.
119. Have you contacted any individual and/or group with regard to Contention 2(c)?
If so, please identify and indicate the reason for contacting any named in-dividual and/or group, the date of the contact, and the individual and/or group response.
120. With respect to individual and/or groups which you may have contacted with regard to Contention 2(c),
have they prepared any documents, undertaken any
. research and/or conducted any studies upon which you will rely?
If so, please describe and provide copies.
121. Do you plan to participate in the upcoming hearing with regard to Contention 2(c)?
If so, please set forth the substance of your participation.
122. Do you plan to file testimony in the upcoming hearing with regard to Contention 2(c)?
If so, who will be the sponsor (i.e.,
witness) of such testimony?
123. Please identify any witness whom you plan to call thebpcominghearingwithregardtoContention at 2(c) and provide a summary of his or her educational and professional background.
Also, please set forth any other information bearing upon his or her quali-fications to testify in this proceeding in this regard.
124. If you plan to call any witness at the upcoming hearing with regard to Contention 2(c), please indicace with specificity the natute of his or her testimony.
In addition, please list and pro-vide copies of documents which any such witness will rely upon with respect to his or her tescimony.
Also, plea e state whether any such witness has undertaken any research, conducted any studies and/
or contacted any individuals and/or groups with reference to his or her testimony.
If so, please describe and provide copies.
125. Do you take issue with the doses set forth in NRC Staff documentation relative to Contention 2(c)?
If so, what is the basis for your objection?
If not, what is the basis for your statement that such dose levels are unacceptable?
126. What is the magniutude of the incremental amount of dose referred to.
127. What is the duration and rate of the exposure used in your estimates?
128. What is: the basis for your dose levels?
129. What is your definition of " vicinity" as used in this contention?
130. What is your definition of " accident" as used in this contention?
131. Please identify the types of accidents considerd, the basis for each accident, dose from each accident, and the mode by which each accident is initiated. What is the magnitude of the accident assumed in this contention?
132. What is your definition of " delay in transit" as used in this contention?
What time period is assumed?
133. Describe, in terms of length of delay, the exact unacceptable incremental burden of radiation dose for people:
(a) within 25 feet of shipment (b) within 50 feet of shipment (c) within 100 feet of shipment (d) within 200 feet of shipment (e) within 300 feet of shipmer.t (f) within 500 feet of shipment (g). within 1000 feet of shipment 134. What is the probability of an accident or delay in transit assumed in this contention?
What is the basis for this response?
135. Please provide all assumptions used for traffic patterns, demographic distribution, and traffic density with respect to location, time of day and accident incidence.
Contention 3 Contention 3 reads as follows:
Intervenors contend that factors set forth in items 1 and 2 above require the preparation of an Environ-mental Impact Statement because the proposed action is a major federal action of the Commission signi-ficantly affceting the quality of the human environ-ment.
136. Do you intend to raise any matters beyond those dis-cussed with respect to Contentions 1 and 2 to sup-port Contention 3?
If so, please provide specific information.
If not, would you agree that this Contention is legal in nature and susceptable to being disposed of by legal argament as opposed to the presentation of direct evidence?
If not, please describe, with specificity, the evidence you would present and provide a copy of your evaluation to support your conclusions.
. Respecttully submitt'
(/
{
J.
[Ilchael ItcGafry, II s
Of counsel:
William L.
Porter, Esq.
Associate General Counsel Duke Power Company March 16, 1979 1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
DUKE POWER COMPANY
)
)
Docket No. 70-2623 (Amendment to Materials
)
License SNM-1773 for Oconee
)
Nuclear Station Spent Fuel
)
Transportation and Storage
)
At McGuire Nuclear Station)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Interrogatories to Safe Energy Alliance (SEA) and Requests to Produce",
dated March 16, 1979 in the captioned matter, have been served upon the following by deposit in the United States mail this 16th day of March, 1979.
Marshall I.
Miller, Esq.
Mr. Jesse L.
Riley Chairman, Atomic Safety and President Licensing Board Carolina Environmental Study U.
S.
Nuclear Regulatory Group Commission 854 Henley Place Washington, D.
C.
20555 Charlotte, North Carolina 28207 Dr. Emmeth A.
Luebke Atomic Safety and Licensing Edward G.
Ketchen, Esq.
Board Counsel for NRC Regulatory U.
S. Nuclear Regulatory Staff Commission Office of the Executive Legal Washington, D.
C.
20555 Director U.
S. Nuclear Regulatory Dr. Cadet H.
Hand, Jr.
Commission Director Washington, D.
C.
20555 Bodega Marine Laboratory of California William L.
Porter, Esq.
Post Office Box 247 Associate General Counsel Bodega Bay, California 94923 Duke Power Company Post Office Box 33189 Charlotte, North Carolina 28242
. Shelley Blum, Esq.
Richard P.
Wilson 418 Law Building Assistant Attorney General 730 East Trade Street State of South Carolina Charlotte, North Carolina 2600 Bull Street 28202 Columbia, South Carolina 29201 Anthony Z.
Roisman, Esq.
Natural Resources Defense Chairman, Atomic Safety and Council Licensing Board Panel 917 15 th S t r ee t, N.W.
U.
S. Nuclear Regulatory Washington, D.
C.
20005 Commission Washington, D.
C.
20555 Brenda Best Carolina Action Chairman, Atomic Safety and 1740 E.
Independence Blvd.
Licensing Appeal Board Charlotte, North Carolina U.
S. Nuclear Regulatory 28205 Commission Washington, D.
C.
20555 Chuck Gaddy Chairperson Davidson PIRG Mr. Chase R.
Stephens P.
O.
Box 2501 Docketing and Service Section Davidson College Office of the Secretary Davidson, North Carolina U.
S. Nuclear Regulatory 28036 Commission Washington, D.
C.
20555 Mr. David R.
Belk Safe Energy Alliance 1707 Lombardy Circle Charlotte, North Carolina 28203 Q
J.
Michael McG4(ry, II