ML20090A688
| ML20090A688 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/05/1984 |
| From: | Bock C BOCK, C.A., NEINER, B. (BOB NEINER FARMS, INC.) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL, NUDOCS 8407120079 | |
| Download: ML20090A688 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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ATOMIC SAFETY AND LICENSING E0ARD O F.
'9 Pl2:46 In The Matter of
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Docket Nos. 50-456
%.,l;g COMMONWEALTH EDISON COMPANY
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50-457
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v; (Braidwood Nuclear Power Station Units 1 and 2 STATUS OF CONTENTIONS - PROPOSED REVISIONS AND AMENDMENTS.
The Petitioners, Bob Neiner Farms, Inc., as authorized by its shareholders; and Bob E. Neiner, Eleanor M. Neiner, Pat Neiner, and Lorraine Creek individually, hereby respond to the Order of the Atomic Safety and Licensing Board of June 8,1984 as follows:
A.
1he above Petitioners, through their attorn'eys, C. Allen Bock and Thomas J. Gordon, do wish to continue as intervenors.
B.
Petitioners statement as to the present status of their contentions:-
Contentions:
- 1. to amendments or revisions.
The petitioners do desire to provide additional research data that has been developed since the original contentions were presented.
- 3. 2 amendments or revisions except that the 20 mile radius is expanded to 25 miles.
- 4. In the matter of contention four we would at this time ask that the Licensing Board be advised of new information about the expected use of the. rail line that lies adjacent to the traidwood facility. We would ask that the following be added to our existing Contention 4.
- 1) The Army is at this time planning to reactivate and enlarge the Joliet Arsenal facility. [ Article in the Kankakee Daily Journal, March 23, 1984 attached as Exhibit A.]
- 2) The Army is presently budgeting between $300,000,000 and
$420,000,000 to reactivate and enlarge the Joliet Arsenal.
- 3) The TNT production facilities are to be enlarged and modernized.
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- 4) The facility is being considered for the production of a new chemical-based explosive.
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,. 5) Due to the increased activity planned at the Arsenal and the change in product production possibilities, the matter of exposure of the Braidwood Plant to increased hazards in relation to the railroad that passes within 1500 feet of the Braidwood Plant, is at,,this time a germane issue to the proceedings.
- 6) We reassert at this time that the actual traffic flow of TNT and other hazardous materials from the Joliet Arsenal that was considered in the initial investigation is not representative of what the actual traffic flow is when the Arsenal is at full production.
- 7) While this country remains at peace the intent,of increased use of the Joliet Arsenal for the production of TNT as well as new product production is very high.
It would surely follow that given a war-time situation the facility would be even more valuable to the Army and the production of goods would be higher, causing increased hazardous rail traffic past Braidwood Plant.
Contentions 5, 6, 7, 8,10, and 11; no revisions or amendments.
C.
Petitioners ask leave to file a contention related to Quality Control considerations.
Nearly five years have elapsed since the amended contentions of Petitioners were filed.
Petitioners 'at this time believe that a Quality Control contention can be developed and filed within 90 days of the date of this answer based on developments during that five year period.
Dated July 5, 1984.
0- h)k~ U C. Allen Bock, Attorney at Law P. O. Box 342, Urbana, IL 61801 (217) 897-6208 Thomas J. Gordon, Attorney at Law Waaler, Evans & Gordon 2503 S. Neil, Champaign, IL 61820 (217)352-7887 l
Attorneys for Petitioners:
Bob Neiner Farms, Inc.
Bob E. Neiner, President and Individually Eleanor A. Neiner Pat Neiner Lorraine Creek i
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Conth.Jed from page 1
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naar Colorr.do Sprin;;s, Colo,137Al'aertn; Fort l'olk, near Leesville,
.-i La., 193,375 acres; and Fort Ord, in northera', California, where e' operations.could be comb!ned with 'srenrby' Fort Hunter,1.iggett, i'...5
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- mere than 70,000, acres:. O t la - ^;';
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. Further Army objections to JAAP center on itsla'ck of training #
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. area, availability of troop bocsing and absence of airfields for J
- strategic deployment, sources said.
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- "Itey're not saying Joliet's off the wall," one, official said.
'"Itey're saying basically it's not a viable alternative to put a light.
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.' r.fantry division there.". f..-
i t.' Marsh said the Army Forces Command in Aticnta would 'make..
the first cut" from 10 to 15 sites it has studied to "four to sir".
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, possibilities within the next two months. -
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't He said survivors of the cut are likely to be installations that' 1
'%' Congressional sources said Army officials were seriously studying.
- l ve barracks and an existing base."
, a less ambitious mission for the mothballed plant that could involve storage for spare parts, beefing up ammunition manufacturing or.,
' ' maintaining or expanding manufactunng for National Guard Re-
' serve and Army. Reserve equ!pment. _
It's that type of use they're locking at," one official,said..
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1 Marsh said there were other options he would urge for consider-
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. ation by. area legislators and damber of commerce officials frein
' Kankakee, Will, Grundy and Kendall Coundes.
.. Those options include "increasmg oncoming contracts" for the
- plant and gearmg it up for the manufacture of RDX-HMX - a new 4
chemical-based explosive to replace TNT.-
"I can tell you that the Undersecretary of the Army, Jim Am.
4 rose' has tracked this very barefully. He feels that Joliet could be.
and should be.an' active competitor" for RDX HMX production,%.
Marsh said..
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Marsh said the new explosive could be produced at several Army sites throughout the huntry within the next few years and JAAP's '
design would make it "a clear competitor in the selectiop prtcess."
And a document from a closed session'between Marsh,and the ; '
.congresmen showed the Army 'is already planning the Joliet plant's
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reactivation.
'.isted under " current activities" was a budget of more than $300 million the Army has planned for upgrading the installation..
7, The plans include $3.63 million for a container distribution facility '
in fiscal 1989; $6.28 million to upgrade TNT production in fiscal 1990 i
to meet worker safety standards; $157.2 million for sulfuric. acid" regenerating plants in fiscal 199t; $59.5 cdllion for llution abated strong nitic acid plants in fiscal 1991; arsd $66.06
'on for a coali.,
fired steam plant in fiscal 199L,
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' The figures apparently do ast include labor costs.
I Although there was no estimate on the cost of preparing the plant for RDX.HMX productioc, the same document revealed the estimat -
- 'ed reactivation cost of the plant to be $420.6 million.
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.'* Most of the money would go for new confiruction 'much of it -
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' cited in the plans for the next seven years.At full mobilization, the documents said, the pla I
' '7,444 people, almost all of them civihana.. ',
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Q.(j(([
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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COMMONWEALTH EDISON COMPANY
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.n DocketNos.50y456-fggd (Braidwood Nuclear Station
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50-457 Bkanc't Units 2 and 2
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CERTIFICATE OF SERVICE I hereby certify that copies of Status of Contentions--Proposed Revisions and Amendments of Bob Neiner Farms, Inc., as authorized by its shareholders; and Bob E. Neiner, Eleanor M. Neiner, Pat Neiner, and Lorraine Creek indivdually, in the above-captioned proceeding have been served on following by deposit in the United States mail, first class, or as indicated an asterisk, Federal Express, on this 5th day of July, 1984.
- Marshall E. Miller, Esq.
Chairman Lorriane Creek Administrative' Judge Route #1, Bcx 182 Manteno, IL 60950 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel
- Dr. A. Dixon Callihan U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.
20555 Union Carbide Corporation P. O. Box Y Docketing and Service Section Oak Ridge, TN 37830 Office of the Secretary U.S. Nuclear Regulatory Comission
- Dr. Richard Cole Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing Board JoAnne Blume, Esq.
U.S. Nuclear Regulatory Comission Isham, Lincoln & Beale Three First National Plaza Washington, D.C.
20555 Chicago, IL 60602 Joseph Gallo Isham, Lincoln & Beale Myron Karman 1120 Connecticut Avenue, NW Office of General Counsel Suite 325 U.S. Nuclear Regulatory Commission 7335 Old Georgetown Road Washington, D.C.
20036 Bethesda, MD 20014
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l Atomic Safety and Licensing Appeal Jane M. Whicher Board Panel BPI l
U.S. Nuclear Regulatory Commission 109 North Dearborn Street Washington, D.C.
20555 Suite 1300 Chicago, IL 60602
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l C. Allen Bock Attorney for Intervenors