ML20111C588

Interrogatories to Bob Neiner Farms,Inc to Identify Sources Providing Basis for Conclusions Re Effects of 765 Kv Transmission Lines.Certificate of Svc Encl.Related Correspondence

ML20111C588
Person / Time
Site:	Braidwood
Issue date:	03/11/1985
From:	Lauer R COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	NEINER, B. (BOB NEINER FARMS, INC.)
References
CON-#185-037, CON-#185-37 OL, NUDOCS 8503150469
Download: ML20111C588 (6)

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ED UNITED STATES OF AMERICA. Jh .

NUCLEAR REGULATORY COMMISSION / 'T ga r tr.,

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In the Matter Of: )

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COMMONWEALTH EDISON COMPANY )

) Docket Noc. 50-4563 C j (Braidwood Nuclear Power ) 50-457o c, t

Station, Units 1 and 2) )

1 INTERROGATORIES TO INTERVENOR j BOB NEINER FARMS, INC., ET AL.

i Applicant, Commonwealth Edison Company, hereby serves upon Intervenor Bob Neiner Farms, Inc., et al.

written interrogatories pursuant to 10 C.F.R. S2.740b. Each interrogatory should be answered separately and fully in writing, under oath or affirmation, within 14 days after service.

1. Identify the document (s) wpich or the per-son (s) whose opinion (s) provide (s) Intervenor's basis for the conclusion that 765 kV transmission lines create each of j the following alleged conditions for persons who are within j 600 feet of the line for six or more hours per day:

a) audible noise impairing hearing; b) increasing tension; c) sleep interference; d) interference with the operation of cardiac pacemakers; i

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e) biological effects on humans because of exposure to electric' fields excluding the use of nearby areas for working, living, or recreation; and f) danger of shock to persons and animals.

2. State with particularity the basis for the assumption that 765 kV transmission lines will be constructed within 600 feet of where persons would have occasion to be for six or more hours per day. If persons exist who would have occasion to be within 600 feet of such lines for six or

more hours per day, identify each such person by name and address.

3. State whether Intervenor agrees that the fields associated with parallel 345 kV and 765 kV lines would be, at worst, only slightly higher than an average of 2.4 kV/m (maximum 6.9 kV/m) for lines at a height of 1 m.

(See Braidwood Final Environmental Statement (FES) at 55.5.1.2 and Braidwood Environmental Report-Operating Li-cense Stage (ER-OLS) at S3.9.6). If Intervenor disagrees i

with this conclusion, state with particularity the basis for such disagreement, and identify all documents or persons upon which Intervenor relies in assessing the accuracy of l this conclusion.

4. State whether Intervenor agrees with the NRC Staff's conclusion in the FES at 55.5.1.2 that "[f]or the most part, adverse effects have been demonstrated only for c

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higher fields (e.g. , greater than 15 kV/m) or longer ex- l posure times than would occur for people residing near or working under transmission lines." If Intervenor disagrees with this conclusion, state with particularity the basis for such disagreement, and identify-all documents or persons upon which Intervenor relies in assessing the accuracy of this conclusion.

5. In light of the NRC Staff's analysis of and conclusions regarding the environmental impacts of postu-lated accidents described in S5.9.4 of the FES, state with particularity the basis for Intervenor's conclusion in Con-tention 7 that "the potential that these facilities would have to be closed, either temporarily or permanently, due to the release of substantial quantities of radioactive ma-terials during an accident creates an unacceptable environ-mental impact."

6. Identify the document (s) which or the per-son (s) whose opinion (s) provide (s) the basis for Inter-venor's conclusion in Contention 7 that "the potential that these facilities would have to be closed, either temporarily or permanenttv. due to the release of substantial quantities of radioactive materials during an accident creates an unacceptable environmental impact."

7. Identify the levels of radioactive release which Intervenor contends would be of " substantial quan-tities" so as to require that the recreational facilities referenced in Contention 7 would have to be closed, tem-porarily or permanently.

8. Identify the type of radiation release at issue in Contention 7.

9. Identify the type of accident postulated in Contention 7, e.g., postulated design-basis accident or a

~ Class 9 accident.

10. Identify by name, title or position, and address all persons Intervenor intends to present as wit-3 nesses to testify with regard to Contentions 1 and 7.

11. Identify the principal spokesperson(s) for Bob Neiner Farms and each individual who formulated or helped to formulate the answers to these interrogatories.

Submitted by:

. /6 One Of The Aqyorneys For' Applicant COMMONWEALTH EDISON COMPANY Joseph Gallo, Esq.

Victor G. Copeland, Esq.

ISHAM,. LINCOLN & BEALE 1120 Connecticut Avenue, N.W.

Suite 840 Washington, DC 20*D36 (202) 833-9730 Rebecca J. Lauer, Esq.

ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200

, Chicago, Illinois 60602 (312) 558-7500 q

I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter Of: )

)

COMMONWEALTH EDISON COMPANY )

) Docket Nos. 50-456 (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I, Rebecca J. Lauer, one of the attorneys for Commonwealth Edison Company, certify that copies of the Interrogatories To Intervenor Bob Neiner Farms, Inc., Et Al.

have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this lith day of March, 1985.

W_th A Rebeccs'J. Lauer ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 DATED: March 11, 1985 i

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i SERVICE LIST q

Lawrence Brenner, Esq. Mr. Scott W. Stucky Chairman Chief, Docketing and Services l Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary

, United States Nuclear Regulatory Washington, DC 20555 l Commission j Washington, DC 20555 4

C. Allen Bock, Esq.

P.O. Box 342 i Dr. Richard F. Cole Urbana, IL 61801 Administrative Law Judge <

Atomic Safety and Licensing j Board Thomas J. Gordon, Esq.

United States Nuclear Regulatory Waaler, Evans & Gordon j Commission 2503 South Neil j Washington, DC 20555 Champaign, IL 61820 Dr. A. Dixon Callihan Ms. Bridget LitL e Rorem i

Administrative Law Judge 117 North Linden Street

,' Union Carbide Corporation Essex, IL 60935 P.O. Box "Y" l

Oak Ridge, TN 37830 Douglass W. Cassel, Jr.

Timothy W. Wright, III Myron Karman, Esq. BPI

, Elaine I. Chan, Esq. 109 North Dearborn Street j Office of the Executive Legal Suite 1300 1 Director Chicago, IL 60602 I

United States Nuclear Regulatory Commission i Washington, DC 20555 Ms. Lorraine Creek Route 1 Box'182 Atomic Safety and Licensing Manteno, IL 60950 i

Board Panel United States Nuclear Regulatory Commission Erie Jones, Director Washington, DC 20555 Illinois Emergency Services and Disaster Agency 110 East Adams Atomic Safety and Licensing Springfield, IL 62705

, Appeal Board Panel i United States Nuclear Regulatory

] . Commission Washington, DC l 20555 l

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