ML20054B768
| ML20054B768 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/15/1982 |
| From: | Mizuno G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | OAK RIDGE, TN |
| References | |
| NUDOCS 8204190180 | |
| Download: ML20054B768 (12) | |
Text
E UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY
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Docket No. 50-537 0
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PROJECT MANAGER CORPORATI0fl
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TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor
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NRC STAFF'S SECOND SET OF 4
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4 IflTERROGATORIES TO THE CITY OF OAK RIDGE e
N Pursuant to 10 C.F.R. 5 2.740(b), the NRC Staff serves the following interrogatories on the City of Oak Ridge (" City"). These interrogatories are substantially the same as the NRC Staff's " Initial Interrogatories to the City of Oak Ridge, Tennessee, dated August 10, 1976, to which the City has not yet responded. The Staff hereby withdraws its First Set of Interrogatories to the City. The interrogatories have been amended to reflect the current projections for construction and operation of the CRBR.
INSTRUCTIONS AND DEFINITIONS 1.
Information sought in these Interrogatories shall include information within the knowledae, possession, control or access of any agents, employees and independent contractors of the City.
2.
Each Interroaatory should be answered in five parts as follows:
a.
Answer the direct question asked or provide the information requested.
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b.
State completely any documents used as the basis for the answer to the interrogatory, c.
State completely any documents consulted, but not relied upon as a basis for preparation of your response to the interrogatory.
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 Staff.
j 4.
For the purposes of this interrogatory, the Clinch River Breeder Reactor will be referred to as CRBR.
INTERR0GATORIES 1.
(a) 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?
(b)
If the answe-to (a) is yes, please provide the results of this study or analysis.
2.
(a) Has the City conducted or analyzed any studies prepared to estimate the expected distribution in the City school systen of
dependents of primary construction workers associated with CRBR?
(b)
If the answer to (a) is yes, describe in detail the results of these studies.
3.
(a) Does the City have data on current enrollment and capacity of City schools which are expected to absorb children of CRBR 1
construction workers?
(b)
If the answer to (a) is yes, please provide this data.
4 (a) Does the City have any plans under discussion or already approved for the capital expansion of City schools identified in interrogatory 4?
(b)
If the answer to (a) is yes, provide a detailed description of these plans.
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5.
(a) Does the City have any data on the number or percentage of City of Oak Ridge pupils currently bussed to school?
(b)
If the answer to (a) is yes, please provide this data.
6.
(a) Does the City believe that the children of primary workers associated with CRBR would alter the percentage of bussed 1
pupils provided in interrogatory 5(b)?
(b) 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)?
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7.
(a) Does the City believe that it will be necessary to finance school system capital construction projects in City because of increased enrollment caused by dependents of primary construction workers associated with CRBR?
(b) If the answer to (a) is yes, please describe in detail the method (s) most likely to be used to finance the school system capital construction projects described in (a).
8.
(a) 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 protection, etc.) expected in the City as a result of CRBR construction?
(b)
If the answer to (a) is yes, please describe in detail the results of this study or analysis.
9.
(a) 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?
(b)
If the answer to (a) is yes, please provide a detailed description of the plan (s).
10.
(a) Does the City have any proposed or approved plans for inceases in City employment to serve the increased demand for City services as a result of CRBR construction?
(b)
If the answer to (a) is yes, please provide a detailed description of the plan (s).
. 11.
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.
12.
If the answer to 11(al 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.
13.
(a) Has the City made or used any projections of the population in the period of 1981-1991 for the City?
(b)
If the answer to (a) is yes, please provide the projections.
I 14.
(a) Does the City have a schedule or projections for new industries or construction projections expected in the City for j
the period of 1981-1991?
(b)
If the answer to (a) is yes, please provide the schedule or projections.
15.
(a)
If the answer to interrogatory 14(a) is yes, does the City i
have employment projections as a result of new industries or construction projects expected in the City in the period between 1981-1991?
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(b)
If the answer to (a) is yes, please provide these projections.
16.
(a) 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 employnent in the City?
(b)
If the answer to (a) is yes, please describe in detail the studies.
(c)
If the answer to (a) is no, does the City have knowledge that a study as described in (a) exists?
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- 17. 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?
(b)
If the answer to (a) is yes, please describe in detail the studies.
1 (c)
If the answer to (a) is no, does the City have knowledge that a study described in (a) exists?
(d)
If the answer to (c) is yes, please provide the title of the study.
18.
(a) Has the City conducted or used any studies estimating the manner in which the lack of public sector service capacity l
i (i.e., roads, sewers, water, school, fire protection, etc.)
might prevent, retard or aggravate growth in the City?
(b)
If the answer to (a) is yes, please describe in detail the studies.
'(c)
If the answer to (a) is no, does the City have knowledge that a study described in (a) exists?
(d)
If the answer to (c) is yes, please provide the title of the study, i
19.
(a) Does the City have under discussion plans or approved plans to improve existing roads or construct new roads in anticipation of CRBR construction related traffic?
(b)
If the answer to (a) is yes, please describe in detail the plans.
20.
(a) 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?
I (b)
If the answer to (a) is yes, please describe in detail the studies.
(c)
If the answer to (a) is no, does the City have knowledge that a study described in (a) exists?
(d)
If the answer to (c) is yes, please provide the title of the study.
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21.
(a) Has the City conducted or used studies relating to the adequacy of the capacity of health services in the City?
(b)
If the answer to (a) is yes, please describe in detail the studies.
(c)
If the answer to (a) is no, does the City have knowledge that a study described in (a) exists?
(d)
If the answer to (c) is yes, please provide the title of the study.
22.
(a) Has the City conducted or used any studies estimating the effect of CRBR construction on the capacity of health services in the City (b)
If the answer to (a) is yes, please describe in detail the studies.
(c)
If the answer to (a) is no, does the City have knowledge that a study described in (a) exists?
(d)
If the answer to (c) is yes, please provide the title of i
the study.
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23.
(a) Does the City have zoning plans under discussion or approved plans to regulate commercial and residential development?
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(b)
If the answer to (a) is yes, please provide a detailed description of these plan (s).
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. 24.
(a) How many acres of privately owned land in the City are zoned for industrial uses?
(b) How many acres M 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?
(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 the answer to (e) above indicates industrially zoned land not served by these capital facilities, does the City have a capital budget or progran to provide such facilities?
Respectfully submitted,
%d. M Gefr Mizuno Cdun for NRC Staff Dated at Bethesda, Maryland this 15th day of April,1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY
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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTHORIlf
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(Clinch River Breeder Reactor
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Plant)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S SECOND SET OF INTERR0GATORIES TO THE CITY OF 0AK RIDGE" and " NOTICE OF APPEARANCE" for Geary S. Mizuno in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by (*) through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by
(**) hand delivery, or as indicated by (***) Express Mail, this 15th day of April, 1982:
Marshall Miller, Esq., Chairman William M. Leech, Jr., Attorney General Administrative Judge William B. Hubbard, Chief Deputy Atomic Safety and Licensing Board Attorney General U.S. Nuclear Regulatory Conmission Lee Breckenridge, Assistant Attorney l
Washington, D.C.
20555
- General 450 James Robertson Parkway l
Mr. Gustave A. Linenberger Nashville, Tennessee 37219 Administrative Judge Atomic Safety and Licensing Board Oak Ridge Public Library U.S. Nuclear Regulatory Commission Civic Center Washington, D.C.
20555 Oak Ridge, Tennessee 37830 l
Dr. Cadet H. Hand, Jr., Director William E. Lantrip, Esq.
l Administrative Judge City Attorney Bodega Marine Laboratory Municipal Building University of California P.O. Box 1 P.O. Box 247 Oak Ridge, Tennessee 37830 Bodega Bay, California 94923 Lawson McGhee Public Library Alan Rosenthal, Esq., Chairman 500 West Church Street Atomic Safety and Licensing Appeal Knoxville, Tennessee 37902 Board Panel U.S. Nuclear Regulatory Commission Warren E. Bergholz, Jr.
Washington, D.C.
20555 Leon Silverstrom U.S. Department of Energy Dr. John H. Buck 1000 Independence Ave., S.W.
Atomic Safety and Licensing Appeal Room 6-B-256 l
Board Panel Washington, D.C.
20585 U.S. Nuclear Regulatory Conmission Washington, D.C.
20555
George L. Edgar, Esq.
Mr. Joe H. Walker Frank K. Peterson, Esq.
401 Roane Street Gregg A. Day, Esq.
Harriman, Tennessee 37830 Thomas A. Schmutz, Esq.
Irvin A. Shapell, Esq.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Project Management Corporation P.O. Box U Oak Ridge, Tennessee 37830 Ellyn R. Weiss **
Dr. Thomas B. Cochran Barbara A. Finamore S. Jacob Scherr Natural Resources Defense Council, Inc.
1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006 Mr. Godwin Williams, Jr.
Manager of Power Tennessee Valley Authority 819 Power Building Chattanooga, Tennessee 37401 Mr. Lochlin W. Coffey, Director Clinch River Breeder Reactor Plant Project U.S. Department of Energy Washington, D.C.
20585 Eldon V.C. Greenberg Tuttle & Taylor 1901 L Street, N.W., Suite 805 Washington, D.C.
20036 t
l Atomic Safety and Licensing Appeal Board Panel l
U.S. Nuclear Regulatory Connission Washington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Conmission Washington, D.C.
20555 Docketing and Service Section
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Office of the Secretary G
U.S. Nuclear Regulatory Commission Ge yA.JMizuno
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Washington, D.C.
20555 C
s W for NRC Staff
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the flatter of UNITED STATES DEPARTMENT OF ENERGY
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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTH0RllY
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(Clinch River Breeder Reactor
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Plant)
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NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the captioned matter.
In accordance with 5 2.713(b), 10 C.F.R. Part 2, the following information is provided:
Geary S. Mizuno
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Name U.S. Nuclear Regulatory Comission Address Office of the Executive Legal Director Washington, DC 20555 Area Code 301 - 492-8505 Telephone Number Admission District of Columbia NRC Staff Name of Party U.S. Nuclear Regulatory Comission Washington, DC 20555 r
izuno V
C un el or NRC Staff Dated at Bethesda, Maryland this 15th day of April, 1982