ML20053D061

From kanterella
Jump to navigation Jump to search
Response to 820415 Second Set of Interrogatories.Affidavits & Certificate of Svc Encl.Related Correspondence
ML20053D061
Person / Time
Site: Clinch River
Issue date: 05/26/1982
From: Cohan P, Faust L, Smallridge R
OAK RIDGE, TN
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8206040014
Download: ML20053D061 (22)


Text

&

k

.at . .

REI.ATED COnnFSPONDEPICB y .--

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'Cl JUN -1 C'. T l IN THE MATTER OF ) /df/f

) .

UNITED STATES DEPARTMENT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION ) DOCKET NO. 50-537

)

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor )

Plant) )

CITY OF OAK RIDGE'S RESPONSE TO THE NRC STAFF'S SECOND SET OF INTERROGATORIES Pursuant to 10 C.F.R. 2.740(b), the City of Oak Ridge hereby responds to the NRC Staff's Second Set of Interroga-tories dated April 15, 1982.

INTERROGATORY I Has the City conducted or analyzed studies which estimate the increased enrollment at City schools which is attributable to the dependents of primary construction workers associated with CRBR?

RESPONSE

The Board of Education has conducted no study with reference to the increased enrollment at City schools which would be attributable to the dependents of primary construction workers associated with the CRBR. The Board of Education has experienced in the past the increased enrollment during periods of construction with similar numbers of workers anticipated for the CRBR. Increases O S3 8206040014 820526 PDR ADOCK 05000537 0 PDR //

have been experienced especially at two schools (Cadar Hill and Willowbrook) which serve areas within the City where the majority of rental properties are found, but the increased enrollment has not been of a great magnitude and the Board believes that there is adequate capacity to accomodate increased enrollment.

INTERROGATORY II Has the City conducted or analyzed any studies prepared to estimate the expected distribution in the City school system of dependents of primary construction workers asso-ciated with CRBR?

RESPONSE

The City has conducted no surveys or analysis but believes that there will be two schools which will receive the majority of students who are dependents of CRBR primary construction workers. The basis of this opinion is the City's experience with similar construction projects and the location of rental properties in these two school dis-tricts.

INTERROGATORY III Does the City have data on current enrollment and capacity of City schools which are expected to absorb children of CRBR construction workers?

RESPONSE

(a) Yes (b) Current enrollment (April, 1982) 4,900 Capacity 6,000 l _ . .

'o n

While the school facilities have projected a capacity of 6,000, the Board of Education believes that actual capa-city is less and would be dependant on age group and distri-bution of students.

INTERROGATORY IV Does the City have any plans under discussion or already approved for the capital expansion of City schools identified in interrogatory 47

RESPONSE

No INTERROGATORY V Does the City have any data on the number or percentage of City of Oak Ridge pupils currently bussed to school?

RESPONSE

(a) Yes (b) Morning (winter) 29%

(spring) 26%

Afternoon (winter) 42%

(spring) 37%

INTERROGATORY VI Does the City believe that the children of primary workers associated with CRBR would alter the percentage of bussed pupils provided in interrogatory 5(b)?

RESPONSE

No substantial increase in the percentage of bussed students is anticipated.

INTERROGATORY VII Does the City believe that it will be necessary to finance school system capital construction projects in

dity because of increased enrollment caused by dnpandants of primary construction workers associated with CRBR?

REf?ONSE No INTERROGATORY VIII Has the City conducted a study or performed an analysis of a study to estimate the increased burden on local public services (i.e., roads, sewers, water, schools, fire protec-tion, etc.) expected in the City as a result of CRBR con-struction?

RESPONSE

(a) The City has analyzed its general revenue sources that support local public services, and has reviewed the scale of CRBR impacts.

(b) Without basing its conclusions on any single study, the City finds it apparent that increased burdens on local public services resulting from CRBR construction will be generally slight, relative to the on-going delivery of ser-vices to the existing residents and employees of industrial and commercial establishments in the area. Presentations by the East Tennessee Energy Projects Coordinating Committee and by Project Management Corporation and East Tennessee Development District staff in June of 1976, as well as Sections 8.0 and Appendix C of CRBRP Environmental Report, Volume 3, PMC, support the scale of impacts.

However, this burden already is distributed far more heavily on local homeowners thar. on the commercial and

industrial sector in Oak Ridge, compared to other Tennoseco cities. Illustrating this fact is the following comparison based on data from The 1980 Annual Survey of State and Local Governments in Tennessee, Tennessee Taxpayers Association, Nashville, November 1980, " Analysis of 1979 Assessed Valua-tions in Certain Cities and Towns," pp. 80-81:

Total Industrial Residential All Other Total

& Conmercial Assess- & Farm Assess- Assess-ments, 7. ments 7. ments Four Metropolitan 47.4 30.6 22.0 100.0 Cities (Chattanooga, Knoxville, Nashville,

- USD & Menphis 1% Other Tennessee 43.2 35.8 21.0 100.0 Cities Oak Ridge 30.0 56.4 13.6 100.0 It is evident that any increase in service costs that is not accompanied by an equivalent or more favorable distri-bution of the tax load between the industrial / commercial sec-tors and the residential sector will only aggravate the exist-ing inequity.

INTERROGATORY IX Does the City have any plans under discussion or approved plans for capital expansion of the City public facilities to serve the increased demand as a result of CRBR construction?

RESPONSE

No INTERROGATORY X Does the City have any proposed or approved plans for increases in City employment to serve the increased demand for City services as a result of CRBR construction?

RESPONSE

No INTERROGATORY XI If the answer to interrogatory 10(a) is yes, describe in detail what method (s) the City is most likely to use to finance new capital construction which is required to serve increased demand as a result of CRBR construction.

RESPONSE

N/A INTERROGATORY XII If the answer to 11(a) is yes, describe in detail what method (s) the City will use to finance increased operating costs of local public sector services as a result of CRBR construction.

RESPONSE

N/A INTERROGATORY XIII Has the City made or used any proj ections of the popu-lation in the period of 1981-1991 for the City?

RESPONSE

(a) Yes, the City has made various projections of its population in the period 1981-1991. The City has noted that such " projections for areas of Oak Ridge's size and age are difficult to formulate accurately, especially when consider-able employment is subj ect to fluctuations on a yearly basis through the Federal budget process. At best, estimates can be expected to be realized within a few years of the dates

anticipated. For this reason, plans should account for population increases without placing too much reliance on proj ection periods."

(b) The attached projection assumed no annexation of residential areas, that population in existing residences will decline, on the average, and that population growth will remain more dependent on housing growth than on fluc-tuations in employment levels, among other assumptions. As conditions change, fresh population projections should be made using appropriate new assumptions.

INTERROGI "0RY XIV Does the City have a schedule or projections for new industries or construction projections expected in the City for the period of 1981-1991?

RESPONSE '

\

(a) No,;the City recognizes that the City's physical area is too small, and the industrial / construction decision arena t'oo vast and far-spread, for meaningful projections regarding industrial investment within the City over a ten-year time span. With confidence that such investment is both likely and desirable, the City has concentrated efforts

, on institutional pathways for acquiring unimproved surplus land,on financing and encouraging the necessary infra-structure, and on making such improved land available to industrial investors in the tax-paying sector. Ther e has been a role for the municipality in such activity that l

l

. 1 i

neither other levels of government (state, federal) nor the private sector could fill, although these other sectors cer-tainly play other, essential roles in this process of increas-ing the City's industrial diversity and self-sufficiency.

1 The City makes every effort to be aware of any new industries or construction projects considered or proposed by various parties, but a long record of postponements, can-cellations and decisions to locate elsewhere suggests that cautious rather than firm optimism is an appropriate City position. Our investments in intra-structure must have a fair chance of leading to investments by industry.

INTERROGATORY XV If the answer to interrogatory 14(a) is yes , does the City have employment projections as a result of new industries or construction projects expected in the City in the period between 1981-1991?

RESPONSE

(a) Although the City has found it cannot rely on schedule proj ections of new industrial development, it remains interested in all such potential developments together with their resulting jobs.

(b) Illustrative of one such projection, the City projected in 1976 that successful development of its Valley Industrial Park, totalling 118 acres, would result in a direct employment impact of between 475 and 900 industrial jobs. In 1976, no single occupant of this park could be identified.

o .

INTERROGATORY XVI Has the City conducted or used any studies estimating the employment or income multipliers for the various types of projects associated with CRBR offering basic industry employment in the City?

RESPONSE

The City has conducted no independent studies estimat-ing the employment or income multipliers for whatever proj ects might be associated with CRBR.

The City has noted the employment multipliers dis-cussed in Section 8 of the CRBRP Environmental Report, Volume 3, PMC, through Amendment 11.

INTERROGATORY XVII Has the City conducted or used studies estimating the amount and distribution, i.e., state, county, local, of various sources of tax revenues expected to be generated as a result of payroll spending by the primary work force of the CRBR during the construction and operational phases of the project?

RESPONSE

The City has conducted no independent studies estimat-ing the amount and distribution of various sources of tax revenue expected from CRBR payroll spending during construc-tion or operation of the proj ect.

The City has noted the analysis of expenditures and revenues in Section 3 of Appendix C of the CRBRP Environ-mental Report, PMC.

e e f

INTERROGATORY XVIII Has the City conducted or used any studies estimating the manner in which the lack of public sector service capa-city (i.e., roads, sewers, water, school, fire protection, etc.) might prevent, retard or aggravate growth in the City?

RESPONSE

The City on many occasions has conducted or issued studies addressing various service capacity limitations and their effect on the City's functioning.

At various times the. City has conducted or used studies that evaluated such services as:

Fire protection and location of fire station; transportation needs and priorities in relation to traffic hazards; overall review of the muni-cipal water distribution system; the solid waste collection and disposal system and the waste water collection and treatment system; the need for and feasibility of a local general aviation airport; and varicus surveys and overviews relat-ing the City's service system to projected needs.

Such studies include:

Fire Department Station Relocation Study, City of Oak Ridge, April 1967; Clinton-Oak Ridge Transpor-tation Study, 1967-1987, Volume I, II, prepared by the University of Tennessee Civil Engineering Department, Knoxville; Engineering Study of Water Distribution System, Pitometer Associates, 1970; Solid Waste Management Report, City of Oak Ridge, December 1974; Airport Feasibility Study, City of Oak Ridge, April 1976; Additions and Modifications to Existing Waste Water Collection and Treatment and related studies (Oak Ridge 201 Feasibility Planning Area), Conseur, Townsend & Associates, March 1974, October 1975, and June 1976; Prelimi-nary Emergency Impact Assistance Plan, East Tennessee Development District, November, May 1940; Hazardous Location Traffic Study, (Anderson Councy),

East Tennessee Development District and Wilbur Smith Associates, 1980.

INTERROGATORY XIX Does the City have under disucssion plans or approved plans to improve existing roads or construct new roads in anticipation of CRBR construction related traffic?

RESPONSE

Road improvements are presently underway in the area in which CRBR is to be located. There are no plans for additional road improvements in anticipation of CRBR con-struction related traffic.

INTERROGATORY XX Has the City conducted or used any studies estimating the cost of road maintenance resulting from heavy trucks or established roads leading to the CRBR site?

RESPONSE

The City has conducted no studies estimating the cost of road maintenance. The City has experienced damages to its roads from heavy trucks using its roads during pre-vious construction proj ects similar to CRBR.

INTERROGATORY XXI Has the City conducted or used studies relating to the adequacy of the capacity of health services in the City?

RESPONSE

The City has conducted no studies and is not aware of the existence of any study relating to the adequacy of health services in the City.

f

- , - - - - , - - -. . , , , , , - , - - - . + - , , ,-m , .-,-- , - , - - e

INTERROGATORY XXII Has the City conducted or used any studies estimating the effect of CRBR construction on the capacity of health services in the City?

RESPONSE

The City has conducted no studies and is not aware of the existence of any study relating to the effect of CRBR on the capacity of health services in the City.

INTERROGATORY XXIII Does the City have zoning plans under discussion or approved plans to regulate commercial and residential development?

RESPONSE

Yes, the City has had an adopted Zoning Ordinance governing its incorporated municipal limits ever since incorporation as a municipality.

The Zoning Ordinance and Zoning Maps (Part "A" and Part "B") are comprehensive zoning regulations adopted by the City of Oak Ridge. The Zoning Ordinance is codified and copies of the same are available for inspection in the City Clerk's office and also at the Oak Ridge Public Li.brary.

INTERROGATORY XXIV (a) How many acres of privately owned land in the City are zoned for industrial uses?

(b) How many acres of land in this category are occupied by industrial uses?

(c) How many acres of privately owned industrially zoned land are occupied by non-industrial land uses? s (d) How many acres of privately owned industrially zoned land are undeveloped?

(e) How many acres of this category of land are served by sewer, by water, and by existing streets?

(f) The answer to (e) above indicates industrially zoned land not served by these capital facilities, does the City have a capital budget or program t.o provide such facili-ties?

RESPONSE

Since the City functions as part of the conduit to move land into private industrial use, the response includes the municipally-owned land as well as the privately-owned land zoned for industrial use where appropriate. Not included are the approximately 37,900 acres of land owned by the U.S. Government (Tennessee Valley Authority or Department of Energy) which are zoned in the industrial categories of Industrial 2 or F.A.I.R., (Forestry, Agriculture, Indus-try and Research). This total includes the CRBR site.

The following information is provided as of May, 1982:

Private Municipal Total (ar.res) (acres) (acres)

(a) lands zoned for industrial 614.43 199.30 813.73 use (Ind-1, Ind-2, F.A. I.R)

(b) Industrially zoned lands 279.01 13.77 292.78 occupied by industrial uses (c) Industrially zoned lands 0 3.52 3.52 occupied by non-industrial uses (d) Industrially zoned lands 335.42 182.01 517.43 which are undeveloped (i.e.

without industrial buildings)

Private Municipal Total (acres) (acres) (acres)

. (e) Portions of undeveloped, 83.01 142.08 225.09 industrially zoned lands which are served by sewer, water, and existing streets (f) 'Ibe City does, in fact, review annually a capital inprovement pro-gram which includes such items as the extension of water, sewer, or streets to inchstrial areas.

4 I

t

... ~. - . , . . . , , . . _ _ _ , , _ - _ _ _ _ _ . , _ _ _ . . . . , . .,

...,__._...._1..~_,____ . _ _ . _ _ , . _ . , _ , _ - . . _ . .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF U.S. DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION DOCKET No. 50-537 TENNESSEE VALLEY AUTHORITY AFFIDAVIT OF ROBERT J. SMALLRIDGE Robert J. Smallridge, being duly sworn, deposes and says as follows:

1. That he is employed as Superintendent of Schools of the City of Oak Ridge and that he is duly authorized to answer interrogatories numbered 1 through 7 in the second set.
2. That the above mentioned and attached answers are true and correct to the best of his knowledge and belief.

SIGNATURE

[

Subscribed and sworn to before me this <I[I ay d of Msx , 1982.

/

Ard d & % Efa b and g DTARY PUBLIC My Commission Expires:

hl.u d /( /9/d~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4

IN THE MATTER OF U.S. DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION DOCKET NO. 50-537 TENNESSEE VALLEY AUTHORITY AFFIDAVIT OF PETER H. COHAN Peter H. Cohan, being duly sworn, deposes and says as follows:

1. That he is employed as Assistant Superintendent for Planning and Finance of the City of Oak Ridge and that he is duly authorized to answer interrogatories numbered 1 through 7 in the second set.
2. That the above mentioned and attached answers are true and correct to the best of his knowledge and belief.

do -

SIGNATURE Subscribed and sworn to before me this J7fA6< lay of 4 9 , 1982.

(/

. Wh$ 52' 8 (bH!sd NQTARY PUBLIC My Commission Expires:

fi$la <-e d l'l /fST

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF U. S. DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION Docket No. 50-537 TENNESSEE VALLEY AUTHORITY AFFIDAVIT OF LUCIEN FAUST Lucien Faust, being duly sworn, deposes and says as follows:

1. That he is employed as Planning Director of the City of Oak Ridge and that he is duly authorized to answer interrogatories numbered 8 through 20, 23 and 24 in the second set.
2. That the above mentioned and attached answers are true and correct to the best of his knowledge and belief.

SIGNATURE

(

Subscribed and sworn to before me this J Y d day of Mw, 1982.

9 My Commission Expires: <A .

p // NOTAIN PUBLIC

/

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF U. S. DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION DOCKET NO. 50-537 TENNESSEE VALLEY AUTHORITY AFFIDAVIT OF M. LYLE LACY M. Lyle Lacy, being duly sworn, deposes and says as

! follows:

1. That he is employed as City Manager of the City of Oak Ridge and that he is duly authorized to answer interrogatories numbered 8 through 24 in the second set.
2. That the above mentioned and attached answers are true and correct to the best of his knowledge and belief.

Du ~

wh SIGNA'T.URE ' l fN Subscribed and sworn to before me this c2M day of M %, 1982.

(

/

(/ // NOTKRY PUBLIC My Commission Expires:

& l '7, /'lfA)

Source: " Oak Ridge Land Use Plan," April 1978 (Discussion Copy) ..

5 Oak Ridge Anderson County Knoxville Knox County Year Population 1 Growth Population  % Growth Population  % Growth Population  % Growth 1950 30,229 - 59,407 - 124,769 - 223,007 -

1960 27,169 -10.1 60,032 1.0 ' ~:1,827 -10.3 250,523 12.3 1970 28,319 4.2 60,300 0.4 174,587 56.1 276,293 10.2 1975 28,000 -1,1 61,911 2.6 179,999 3.0 303,379 9.8 1980 30,100 2 7.5 64,909 4.8 181,918 1.0 335,298 10.5 1985 32,000 2 6.3 69,948 7.8 182,910 0.5 360,057 7.4 32,500 2* 74,988 7.2 183,122 0.1 374,431 4.3 1990 1.6 Table 1 Actual and Projected Population for Oak Ridge and Surrounding Areas

  • This figure is projected to remain constant for the years 1995 & 2000 Sources: I Land Use Marketability Study, University of Tennessee,1977; plus Planning Office revisions

- - - - - - , , c, 1 s  ;

o 1 m

.c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.. c n. A g/l In the Matter of )

r UNITED STATES DEPARTMENT OF ENERGY )

PROJECT MANAGEMENT CORPORATION ) DOCKET No. 50-537 TENNESSEE VALLEY AUTHORITY )

(Clinch River Breeder Reactor Plant) )

CERTIFICATE OF SERVICE Service has been effected by deposit in the United States mail, first class, on this date, the 26th day of May 1982, to the following:

Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545 Dr. Cadet H. Hand, Jr.

Director Bodega Marine Laboratory University of California P. O. Box 247 Bodega Bay, California 94923 Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545 Daniel Swanson, Esquire Stuart Treby, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20545 Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545

Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20545 Docketing & Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20545 The Honorable William M. Leech, Jr.. Attorney General The Honorable William B. Hubbard, Chief Deputy Attorney. General The Honorable Lee Breckenridge. Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ri_dge, Tennessee 37830 Herbert S. Sanger, Jr.. Esquire Lewis E. Wallace, Esquire W. Walter LaRoche. Esquire James F. Burger, Esquire Edward J. Vigluicci. Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 Dr. Thomas Cochran Ms. Barbara A. Finamore Natural Resources Defense Council 1725 Eye Street, N.W., Suite 600 Washington, D. C. 20006 Mr. Joe H. Walker 401 Roane Street Harriman. Tennessee 37748 Ms. Ellyn R. Weiss Harmon & Weiss 1725 Eye Street. N.W., Suite 506 Washington, D. C. 20006 Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902

George L. Edgar, Esquire Morgan, Lewis & Bockius 1800 M Street.. N.W. ,

Washington, D. C. 20036 l Leon Silverstrom, Esquire Warren E. Bergholz. Esquire U. S. Department of Energy 1000 Independence Avenue, S. W.

Room 6B-256 Washington, D. C. 20585 Eldon V. C. Greenberg. Esquire Tuttle & Taylor 1901 L Street, N.W., Suite 805 Washington, D. C. 20036.

Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 4

kt 88-m b.

William E. Lantrip5 M) b Attorney for City of Oak Ridge i

.- . _ _ _ . . . - _ . . . . _ ,_.. _ _ _ _ _ _ _ , , . . . _ .-