ML20116L730

Answers to Interrogatories Requested by NRC Re Contention 4. Certificate of Svc Encl.Related Correspondence

ML20116L730
Person / Time
Site:	Braidwood
Issue date:	04/30/1985
From:	Bock C BOCK, C.A., NEINER, B. (BOB NEINER FARMS, INC.)
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#285-838 OL, NUDOCS 8505030708
Download: ML20116L730 (5)

Text

Di anmacousseagg UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOLMETEC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD USNRC In the Matter of: ) W -3 All 24

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COMMONWEALTH EDIS0N COMPANY ) 0FFici gr gg, , -.

) Docket Nos. 50-456(ECCMETmc A M_y;'

) 50-457 BRANCH (Braidwood Nuclear Power Station, Units 1 and 2) ) .

BOB NEINER FARMS, INC., ET AL.

ANSWERS TO INTERROGATORIES REQUESTED BY NRC STAFF Contention #4

. Interrogatory #1. Is the Intervenor aware of any evidence (other than exhibit A of the proposed revisions and amendments to their contention (s) which supports any of the following with respect to the Joliet Arsenal facility:

a) plans to " reactivate," " enlarge," or " modernize,"

b) plans to budget "between $300,000,000 and $420,000,000" for reactivation and enlargement, or c) plans for the production of a "new chemical-based explosive."

If the answer is yes, identify all such evidence (e.g. documents, reports, studies) and provide complete citations.

Answer #1, Intervenor via a telephone conversation with Mrs. Jean Duncan, a staff member in Congressman Edward Madigan's office, was told the following:

,A. House Report 981159 provided the funding for a feasibility study which has not yet been completed.

B. $32,000,000 was appropriated for a study of all facilities that are capable of producing RDX-HMX. $10,000,000 of this $32,000,000 has been allocated to a study of the Joliet Plant.

Interrogatory #2. Has the Intervenor obtained any evidence or performed analyses which establsh a quantitative relationship between the contended reactivation and enlargement of the facility operations and the frequency of explosives shipments on the Illinois Central Railroad near the Braidwood site. If the answer is yes, identify the evidence (e.g., documents, studies) and provide complete citations.

Answer #2. Not at this time, b

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Interrogatory #3. Is the Intervenor aware of the technical bases and assumptions used by the Staff in determining the Braidwood, Unit 2 safety 3

evaluation findings regarding the explosives shipments on the Illinois Central

.. Railroad? If the answer is yes, identify relevant documents or reports and provide complete citations.

l 1 Answer #3. Not at this time.

Interrogatory #4. Part of Contention 4 alludes to the use of the  :

i Illinois Central La11 road for transport of explosive materials from "other plans '

or depositories." Has the Intervenor established the extent of the contribution f of such shipments to the overall traffic of explosives on the Illinois Central Railrosd? If the answer is yes, ident'ify the evidence (documents, studies,

, reports, analyses) which support the Intervenor's estimates.

4 Answer #4. Not at this time.  :

Interrogatory #5. Has the Intervenor estimated the overpressures that '

j may impact the Braidwood safety-related structures in the event of an explosives detonation on the Illinois Central Railroad? If the answer is yes, identify all

- relevant documents, studies, or analyses, and provide complete citations.

! Indicate the assumptions and the methodology used in making the estimates. -

Answer #5. Not at this time.

Y Interrogatory #6, Has the Intervenor estimated the probability of an explosion of an explosives shipment on the Illinois Central Railroad near the Braidwood site? If the answer is yes, identify all relevant documents, studies, i or analyses, and provide complete citations. Indicate the assumptions and the

! methodology used in making the estimates, including the traffic frequency.

Answer #6. Not at this time.

l

! Interrogatory #7. Is the Intervenor aware of the maximum overpressures that the Braidwood, Unit 2 safety-related structures are designed i

to withstand? If the answer is yes, identify the relevant documents, studies, or reports which support your understanding of the capabilities of Braidwood, Unit 2 safety-related structures to withstand detonation overpressures.

Answer #7. Not at this time.

Interrogatory #8. Is the Intervenor aware of the nature and composition of the explosives that were being shipped from the Joliet Arsenal during the six-month period in 1974 referred to in Contention 47 If the answer is yes, identify all relevant documents and reports and provide complete

citations.

Answer #8. Not at this time.

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4 Interrogatory #9. With respect to the contention that "new chemical-based explosives" are being considered for production at the Joliet Arsenal, is the Intervenor aware of the specific nature of these explosives in terms of their blast characteristics ~t If the answer is yes, identify relevant documents and reports, and provide complete citations.

Answer #9. ?!ot at this time. -

3 Lorraine Creek and C. Allen Bock formulated the answers to these interrogatories.

I, C. Allen Bock, upon information and belief and being first duly sworn, submit the foregoing answers to th i gatories.

Subscribed and sworn to before me C. ATien Bock a Notary Public, this 30th day of For the Intervenor '

b6 b C. Allen Bock -

P.O. Box 342 Urbana, IL 61801 Express mail to:

C. Allen Bock 151 Sevier Hall 905 S. Goodwin Urbana,'IL 61801 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPNISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD bSh['

In the Matter of: )

D #Ay3 g,,

COMMONWEALTH EDISON COMPANY cr -

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I (Braidwood Nuclear Power h0-45 C.

Station, Units 1 and 2)

CERTIFICATE OF SERVICE I, C. Allen Bock, attorney for Intervenor, certify tilat copies of the Answers to Interrogatories Requested by NRC Staff have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 30th day of April,1985. ,

\ u C.(dNnen Bock C. Allen Bock P.O. Box 342 Urbana IL 61801 217/897-6208 DATED: April 30, 1985

SERVICE LIST Lawrence Brenner, Esq. .Mr. Scott W. Stucky Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Board Commission U.S. Nuclear Regulatory Cannission Office of the Secretary Washington, DC 20555 Washington, DC 20555 Dr. Richard F. Cole Thomas J. Gordon, Esq.

Administrative Law Judge 206 N. Randolph Atomic Safety and Licensing Board Chanpaign, IL 61820 U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. A. Dixon Callihan Ms. Bridget Little Rorem Administrative Law Judge 117 North Linden Street Union Carbide Corporation Essex, IL 60935 '

P.O. Box "Y" Oak Ridge, TN 37830 Myron Karman, Esq. (express mail) Douglass W. Cassel, Jr.

Elaine I. Chan, Esq. Timothy W. Wright, III Office of the Executive Legal Director BPI U.S. Nuclear Regulatory Commission 109 N.

Dearborn Street,

Suite 1300 Washington, DC 20555 Chicago, IL 60602 Atomic Safety and Licensing Board Panel Erie Jones, Director U.S. Nuclear Regulatory Connission Illinois Emergency Services and Washington, DC 20555 Disaster Agency 110 E. Adams Atomic Safety and Licensing Springfield, IL 62705 Appeal Board Panel U.S. Nuclear Regulatory Connission Rebecca J. Lauer (express mail) ,

Washington, DC 20555 Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, IL 60602 Joseph Gallo, Esq.

Isham, Lincoln & Beale Suite 840 1120 Connecticut Avenue, N.W.

Washington, DC 20036

.