ML20053D613

Third Set of Interrogatories & Requests for Admissions

ML20053D613
Person / Time
Site:	Clinch River
Issue date:	06/03/1982
From:	Mizuno G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	OAK RIDGE, TN
Shared Package
ML20053D614	List: ML20053D613 ML20053D617
References
NUDOCS 8206070124
Download: ML20053D613 (11)

Text

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06/03/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of.

UNITED STATES DEPARTMENT OF ENERGY )

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

{

TE14NESSEE VALLEY AUTHORITY h

(Clinch River Breeder Reactor

)

Plant)

)

11RC STAFF'S THIRD SET OF INTEIMOGATORIES A!;D REQUEST FOR ADMISSIONS TO THE CITY OF 0AK RIDGE Pursuant to 10 C.F.R. 5 2.740(b), the NRC Staff serves the following interrogatories on the City of Oak Ridge (" City"), to be answered by June 18, 1982 as prn;ided in the Board's February 11, 1982 Order.

l INSTRUCTIONS AND DEFINITIONS 1.

Information sought in these Interrogatories shall include in-formation within the knowledge, possession, control or access of any l

agents, employees and independent contractors of the City.

l 2.

Each Interrogatory should be answered in five parts as follows:

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A.

Answer the direct c,uestion asi ed or provic'e the information requested.

l b.

State completely any documents used as the basis for the ansewr to the interrogatory.

c.

State completely any documents consulted, but not relied upon as a basis for preparation of your response to the interrogatory.

8206070124 820603 POR ADOCK 05000537 Q

0 PDR b

. d.

Give the name and professional qualifications of any individual who will testify on behalf of the City as to the answer given in the interrogatory.

Include a statement of professional qualifications for any identified individual, e.

Give the name and address of any individual, corporation, business, professional association, state or local official; or other organization which served, serves, or it is planned will serve as advisor, witness or consultant to the City on the issue addressed in each interrogatory.

3.

Where an interrogatory requests a description of the results of a study, the City may instead provide a copy of the complete study to the g

Staff.

4.

'1r the purposes of this interrogatory, the Clinch River Breeder Reactor wit. be referred to as CRBR.

INTERROGATORIES 25.1/ escribe the City of Oak Ridge's Zoning Ordinance.

In lieu of D

answering this interrogatory, provide two copies of the City's Zoning Ordinance.

26.

What are the City of Oak Ridge's ordinances or regulations regardir5 the use of cchile bmos as residences?

In lieu of answering this interrogatory, you may provide two copies of the City's ordinances or regulations regarding the use of mobile homes as residences.

-1/

The numbering of the interrogatories is integrated with the NRC Staff's (" Staff") Second Set of Interrogatories to the City of Oak Ridge. Since the last interrogatory of the Staff's Second Set was Interrogatory 24, the next interrogatory is properly designated as Interrogatory 25.

. 27.

Describe all road improvements referred to in the City's response to Interrogatory 19.

In particular, identify the road being improved, the nature of the improvement, the location of the improvenent, expected completion date, total road miles affected by each improvement project, and any estimates o.f road capacity" increases due to the improvements.

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Identify the location of each road improvement on a map of the City.

28. According to the City's May 26, 1982 Answer to the Staff's Interrogatory 24, 292.78 acres out of a total 813.73 acres zoned for 9

industrial use are actually occupied by industrial uses.

In light of the substantial under-utilization of industrial-zoned land, explain why the City believes there will be a tax revenue " loss" resulting from the commitment of the Clinch River site to the CRBR project.

O

. REQUEST FOR ADMISSI0ft Pursuant to 10 C.F.R. 5 2.742, the NRC Staff requests admissions by the City of Oak' Ridge separately and fully, by June 18, 1982, to make the following admissions as to the tr.;th of the.specified inatters of fact.

For each of.the' followingf admissidns' which are denied or which you are

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unable to admit or deny as to their truthfulness, provide the following infonnation:

a.) The portion of the statement which is not admitted.

b.) The basis of your disagreement with the statement.

c.) The expert witnesses, if any, you are relying on in disagreeing with the statement.

d.) The document, if any, you are relying on in disagreeing with the statement.

e.) The articles, if any, you arE relying on in disagreeing with the statement.

REQUESTS 1.

The NRC Staff has adequately analyzed the environmental and socio-economic impacts associated with the CRBR in its Final Environmental l

Statement ("FES"), dated February 1977, up to the date of publication of l

the FES.

2.

The proposed CRBR site consists of 1364 acres owned by the U.S.

government, and is presently in the custody of the Tennessee Valley l

Authority ("TVA").

3.

The CRBR site is located in Roane County, Tennessee, about l

22 miles west of the city of Knoxville. Nearby cities are Kingston, i

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_ _. 7 niles west of the CRBR site; Harriman,10 miles west-northwest; and Cak N dy, 9 niles northeast.

4.

The CRBR site is zoned Industrial 2 by the City of Oak Ridge, and is located in the southwestern corner of.the City of Oak Ridge.

5.

The Clinch Rivei Consolidated Industrial Park, consisting of approximately 112 acres, is adjacent to the north boundary of the CRBR plant site.

6.

Within a 50 mile radius of CRBR, Knoxville and Oak Ridge are the largest cities, with 1980 populations of 183,139 and 27,662 respectively.

7.

The 1980 resident populations within a 10 and 50 mile radius of the CRBR are 52,040 and 830,840 respectively. The 2030 resident popula-tions are estimated to be 67,580 and 933,280 respectively.

8.

The 1980 resident equivalent population within 10 miles of the CRBR, which is defined by the Staff as the sum of the 1980 resident population and the transient, visitor, and commuter population travelling into the area, is 19,640.

The 2030 resident equivalent population is estimated to be 30,738.

9.

Anderson, Knox, Loudon and Roane Counties, which are expected to experience the bulk of the impact due to construction and operation of CRBR, have a combined 1980 population of 464,018. The 2030 population.

fo-these four counties is estimated to be 523,252.

10. The City of Oak Ridge represents about 50 percent of the popu-l lation of Anderson county.

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. 11. Per capita income averages of Anderson and Knox Counties are above those of Loudon and Roane Counties, as well as for the State of Tennessee.

12.

Existing residents of the four counties of Anderson, Knox, Loudon and Roane would supply most of the demand for construction workers for CRBR, through release of workers from other construction projects, movement of workers as they are bid away from other industries, and a decline in unemployment.

13. The Applicants have analyzed socio-economic impacts based upon 26 percent, and 40 percent immovement of construction labor. These figures are based on TVA experience in nuclear power station construction.

14. Applicants adopted an employment multiplicr value c' 1.6, which reflects the temporary nature of impacts associated with the construction of CRBR. This employment multiplier is appropriate for estimating the secondary employment generated by CRBR construction.

15. Applicants assumed that additional indirect employment generated by CRBR construction would not result in the in-migration of workers.

Therefore, total levels of imovement would not be affected by the number of indirect jobs created.

16. At an in-movement level of 26 percent, up to 1300 direct employees may move into the four-county impact area during the peak year of construction. At an in-novement level of 40 perccrt, that figure would be 1600.

17. TVA studies indicate that 70 percent of the employees moving into an area are accompanied by their families, which contain 3.2 persons on average.

It is reasonable to believe that these estimates would i

apply to workers for the CRBR.

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. 18. Assuming the factors described in Admissions 13 through 18, the total number of in-movers would be 3200, assuming a 26 percent in-movement level. At a 40' percent in-movement level, the total number of in-movers would be 5040.

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19. Table 8.3-3 of the Applica'nts' Environmental Report ("ER")

ar.curately surmarizes the estimated number and location of relocating CRBR eupinyees, and children of school age at the peak of construction activity.

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20. Table 8.3-4 and Appendix Table 2.1-8 of the CRBR ER accurately sunnarizes the estimated types and location of residence of relocating CRBR employees.

21.

Knox County would experience the greatest demand for housing, and Roane County would experience the greatest demand for mobile home sites, should the CRBR be constructed.

22. Construction workers who do not relocate in order to be employed at the CRBR project would not cause any social impacts, except for possible traffic problems, since they would use the same public and private sector services and resources they have always used.

23. Only the connunities cf Kingston, Lenoir City, and Oak Ridge would experience housing pressures under both 26 and 40 percent worker in-movement levels.

24. The Applicants' analysis of housing impacts in the ER is con-servative, since the ER does not consider the following mitigating factors:

a.

in-moving workers unaccompanied by families.

b.

single workers, which typically constitute 30 percent of the total workforce.

. c.

use of hotels and motels as transient housing.

d.

doubling-up of single workers in hotels and motels, or other housing.

25. Table 8.1-15 of the CRBR ER accurately presents area school capacity and enrollment figures. for, counties and school systens for the dLL-M scbcol yrer.

.0.

7c 001 Pit'& rti.cci systerr presently has approximately an 18.7 percent excess capacity.

27. Table 8.3-5 and Appendix Table 2.2-8 of the CRBR ER accurately presents area school capacity, enrollment and excess capacity figures for the peak year of CRBR plant construction.

28. During the peak year of CRBR plant construction, the City of Oak Ridge school system will probably experience excess capacity.

29. The Applicants' analysis of school system impacts in the CRBR ER, including the data presented in the ER tables, did not consider private schools as a potential resource, which would reduce the impact of CRBR workers' children on the area school systems.

.V. TI'c Stare cf Tera.cssrc Pepartr:ent of Public Health has issued rp.-spetFir projections of populations which indicate an overall 6 percent decline in school-age children in the four county areas between 1980 and 1985. The State's projections are in conflict with the four county area school authorities, who predict increasing school enrollment.

31. Table 8.1-18 of the CRBR ER accurately presents the number and location of hospital beds, physicians and dentists in the four county impact area.

32. Hospitals in the four county area are at most 76 percent occupied.

. 33. There would be a minimal impact to health care in the four county area attributable to increased needs for health care services by CR8R workers an8 their faniliies.

34. Table 8.1-16 of the CRBR ER accurately presents water sources, treatment capacities, and'consumpt'io'n rates for major water supply systems in the CRBR area.

35. The City of Oak Ridge derives its water from the Clinch River, and its water supply system is operating at about 60% of capacity.

36. One half of the current excess capacity in the four county area water supply systems could supply 150,000 people at a 15 gpd consumption rate. This additional population exceeds by a considerable margin the expected residential population growth from 1980 to the 1985 predicted peak year of construction, plus a 40 percent worker in-movenent assunption.

37. Table 8.1-17 accurately presents wastewater treatntr.t cancities and average daily flows for major waste water treatment systems in the four county area.

38. The City of Oak Ridge's wastewater treatment is operating at I

about 60% of capacity.

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39. One half of the existing excess capacity in the four county l

area wastewater treatment systems could serve the needs of the anticipated resident and 40 percent construction worker in-mover populations, assuming j

a 100 gpd per capita service need.

l

40. Approximately 528 tons of solid waste area collected and disposed i

of by the four counties in the CRBR area.

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. 41. Approximately 10 tons of solid waste or 1 percent of the total solid waste collected in the four county area, will be generated by the in-movement population, assuming a 40 percent inmovement level. This is an insignificant incremental addition to the solid was'te needs of the four county area.

42. Table 8.1-19 accurately presents the number and distribution of law enforcement officers and firemen in the four county area.

43. Expansion of safety services will not be required to accommodate the temporary influx of CRBR workers.

44. The direct project construction payroll is estimated to be

$446.2 million throughout the construction period, in 1981 dollars.

45. The indirect (induced) employrent payrc11 is estinated to be

$2.5 million throughout the construction period, in 1981 dollars.

46.

$179 million would flow to the private sector, assuming a local expenditure rate of 40 percent.

47. The City of Oak Ridge's general fund revenues attributable to CRBR during the peak year of construction, which includes property, sales, beverage, and miscellaneous tax revenues, is equal to $8.080 million.

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48. The City of Oak Ridge's incremental school fund revenues at-l tributable to CRBR during the peak year of construction,..Sich includes property and sales tax, and State equalization funds, is equal to $10.180 million, assuming a 26% worker in-movement level.

49. The total incremental revenue collected by the City of Oak Ridge which are attributable to CRBR is equal to $18.260 million.

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. 50. During the peak year of construction, the City of Oak Ridge will incur approximately $3.980 million in educational costs, assuming a-26 percent worker in-movement level. The educational costs incurred is

$7.960 million, assuming a 40 percent worker.in-moveme'nt level.

51. During the peak [ year of'co'nstruction, the revenue-cost balance for the City of Oak Ridge is $6,200 million, assuming a 26 percent con-struction worker in-movement level. The revenue-cost balance is $7.760 million, assuming a 40 percent worker in-movement level.

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52. The level of service for all road sern:nts in the C0J?. rrn= it the same or higher trer 1ic retei !r nice it rt : 1 irerr tie 1. Cl.LI, tref 4 c is on the road.

53. The most noticeable traffic impact during the CRBR construction l

period will be an extension of peak from 1 to 2 consecutive hours during the peak of construction.

Resp.'ctfully submitted, Gea y S.

izuno Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of June, 1982 A