ML19282C110
| ML19282C110 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 02/16/1979 |
| From: | Blum S BLUM & SHEELY |
| To: | |
| References | |
| NUDOCS 7903200323 | |
| Download: ML19282C110 (3) | |
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UNITED STATES OF AMERICA h
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NUCLEAR REGULATORY COMMISSION to Y* v'*
S In the Matter of
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4e j '. # g DUKE POWER COMPANY la 3.,.
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(Amendmen t to Materials License
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Docket No. 70-2623 SNM-1773 for Oconee Nuclear
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Station Spent Fuel Transportation
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and Storage at McGuire Nuclear
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Station)
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RESPONSE TO APPLICANT'S OBJECTION AND tiOTION FOR PROTECTIVE ORDER Applicant has moved for a protective order covering a series of questions asked by intervenor. The answers to these questions are relevant to matters of inquiry, should intervenor's contentions be approved.
In particular, the substance of these questions are as follows:
The request for the results of a post Irradiation inspection relate to Intervenor's desire to know whether Applicant checks for leaks.
Transporta-tion of leaky assemblies involves different hazards in the event of an acci-dent than does transportation of a non-leaky assembly. The key in this ques-tion is whether Applicant plans to weed out leakers in the transportation program.
The question '..volving the negative salvage value of the fuel assem-blies goes to the issue of whether the real reason, or a contributory reason, for the movement of this fuel is that, in Mecklenburg County, it has a higher value than it does in the county in which Oconee is located. That is, since Mecklenburg tax rates are higher, a substance with a negative value would lower the tax hurden on Applicant.
This motive, which has nothing to do with safety or necessity, is pertinent to the issue as it relates to gcod faith.
Thus, the answers to 45(a) and 46(a) are relevant to the inquiry.
7903200323 The answer to question 64(a) is also needed in order to provide a close look at the alternative of building a new fuel pool.
In particular, since the Federal Government has now announced that it could build a fuel pool which would absorb the production of 72 reactors for fif ty years at a cost of $300,000,000.00, Duke's figure of $40,000,000.00 for its fuel pool for one reactor must be closely examined. The only way to closely examine this is to get estimates for the building of each particular element of a new fuel pool.
Intervenor believes this would demonstrate that the $40,000,000.00
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figure is a gross overestimate.
Intervenor's response to discovery question 74 gives the following figures:
Structure, S5,113 (millions); Equipment, 14,666; Engineer, labor, overhead $12,332; and contingencies and interest,
$12,204, giving a total of $44,315,000.00 (1976). A breakdown is needed in order to see whether some of the equipment is duplicated, much of the engin-eering has been done, what sort of contingencies are expected, and generally why a structure which is repetitive would cost as much as projected.
Wherefore, intervenor moves for full and complete discovery in this mat-ter.
Dated:
February j((,1979 BLUM AND SHEELY by
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SHEELEY' SLUM ' ' '
418 Law Building 730 East Trade Street Charlotte, North Carolina 28202 (704) 376-6591
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS10N BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DED CCPN -
in the Matter of
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DUKE POWF.R COMPANY
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Docket No. 70-2623 3
(Arendment of Materials
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//f License SNM-1773 for Oconee
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a \\Ngg Nuclear Station Spent Fuel
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4 Transportation and Storage
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t at McGuire Nuclear Station)
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CERTIFICATE OF SERVICE t
hereby certify that copies of the foregoing material, dated $s.lf.. /6 I
1979, have been served upon the follow!ng by deposit in the United States mail this i day of
%A n w 1979 a
Mr. Jesse L. Riley, President Chairman, Atomic Safety and Carolina Environmental Study Group Licensing Board 854 Henley Place U.S. Nuclear Regulatory Comnission Charlotte, N.C.
28207 washington, D.C.
20555 Edward G. Ketchen, Esq.
Dr. Emmeth A. Luebke Counsel for NRC Regulatory Staff Atomic Safety and Licensing Boarc U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 washington, D.C.
20555 William L. Porter, Esq.
Dr. Cadet H. Hand, Jr., Director Duke Power Company bodega Marine Laboratory of California P.O. Box 2178 P.O. Box 247 Charlotte, N.C.
28242 Bodega Bay, CA 94923 Geoffrey Owen Little Anthony Z. Roisman, Esq.
Davidson PIRG Natural Resources Defense Council P.O. Box 2501 017 15th St., NW Davidson, N.C.
28036 Washington, D.C.
20005 Chai rman, Atomic Safety and Brenda Sest Licensing Board Panel Carolina Action U.S. Nuclear Regulatory Commission 1740 E.
Independence Blvd.
Washington, D.C.
20555 Charlotte, N.C.
28205 Chai rman, Atomic Sa fety and Richard P. Wilson Licensing Appeal Board Assistant Attorney General U.S. Nuclear Regulatory Commission State of South Carolina Washington, D.C.
20555 2600 Bull St.
Columbia, S.C.
29201 M r. Chase R. Stephens Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 SHELLEY BLuh, 418 Law Bldg.
Charlotte, N.C. 28202