ML20116M999

Responds to Interrogatories Requested by Applicant Re Environ Effects of 765-kV Transmission Lines.Certificate of Svc Encl.Related Correspondence

ML20116M999
Person / Time
Site:	Braidwood
Issue date:	04/29/1985
From:	Bock C BOCK, C.A., NEINER, B. (BOB NEINER FARMS, INC.)
To:
References
CON-#285-847 OL, NUDOCS 8505060447
Download: ML20116M999 (7)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I 00LMETED l'SNRC In the Matter of: )

) '85 MY -3 4125 COMMONWEALTH EDISON COMPANY )

) Docket Nos. 50-45gICE OF SECREnj -

(Braidwood Nuclear Power )

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50-457*#j$,Icf*k1 ANSWERS TO INTERROGATORIES REQUESTED BY APPLICANT COMMONWEALTH EDIS0N COMPANY BY INTERVEN0R B0B NEINER FARMS, INC., ET AL.

Intervenor, Bob Neiner Farms, Inc., et al. hereby responds to the written interrogatories pursuant to 10 C.F.R. 2.740b requested by Applicant.

Interrogatory #1. Identify the document (s) which or the person (s) whose opinion (s) provide (s) Intervenor's basis for the conclusion that 765 kV transmission lines create each of the following alleged conditions for persons who are within 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; 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.

Answer fl. a),b),c),d),e),f)

- "Potential Environmental Effects of 765-kV Transmission Lines: Views Before the New York State Public Service Commission, cases 26529 and 26559, 1976-78," 00E/Ev0056, (Government Accession No.), U.S. Department of Energy, November 1979. Available from: National Technical Information Service, U.S.

Department of Commerce, 5285 Port Royal Road, Springfield, VA 22161 (copy attached as Item A).

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-State of New York Public Service Commission Ooinion No. 78-13, (case 26529 and 26559) (0 pinion and order detennining health and safety issues, imposing operating conditions, and authorizing, in case 26529, operation pursuant to these conditions). Issued June 19, 1978.

. . .., Also:. , State of New York Public Service Connission Opinion No. 76-12.

Issued June 30,1976. (copy attached as Item B).

-Project Resumes " Biological Effects From Electric and Magnetic Fields Associated with High Voltage Transmission Lines,"

U.S. Department of Energy Division of Electric Energy Systems Washington, D.C. 20585 Electric Power Research Institute Health Studies Program Palo Alto, CA 94303 State of New York Department of Health New York State Power Lines Project Albany, NY 12201

- "Biological Effects of High Voltage AC Transmission Lines - Colstrip Project: Garrison-Spokane HVTL," A. R. Sheppard, Redlands, CA. February 1983.

Prepared for Montana Department of Natural Resources and Conservation.

- "Agreement Between New York State Public Service Commission and Power Authority of State of New York Concerning Operation of Massena-Marcy 765kV Transmission Line." (attached as Item C).

-New York State Department of Health Center for Laboratories and Research, Albany, New York 12201 - Memorandum, April 5,1984. (attached as Item D).

-The New York State Power Lines Project Notice of Public Meetings and Report on the Status of the Projects. (attached as Item E).

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Interrogatory #2. State with particularity the basis for the assumption that 765kV 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.

Answer #2. Interv'enor'bblieves that~ testim'ony before the Illinois Commerce Commission by Applicant indicated that there had been acquisition of transmission right of way for the 765k'V transmission line by Applicant.

Recorder's Office of Kankakee County, Illinois, showing right of way easement acquisitions by Applicant.

Pat Neiner Bob E. Neiner Pat Michael Neiner Eleanor M. Neiner Bob Anthony Neiner R. R. #1, Box 139 R. R. #1, Box 139 Manteno, IL 60950 Manteno, IL 60950 Interrogatory #3. State whether Intervenor agrees that the fields associated with parallel 345kV and 765kV 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 5.5.1.2 and Braidwood Environmental Report-0perating License Stage (ER-OLS) at 3.9.6)." 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.

Answer #3. Intervenor disagrees with this conclusion because the conclusion is based on construction plans which the Intervenor believes are not final and, in addition, the conclusion is dependent on the configuration of the lines and the size of the wire bundles. Also see the New York Hearing Report earlier cited. l l

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Interrogatory #4. State whether Intervenor agrees with the NRC Staff's conclusion in the FES at 5.5.1.2 that "[f]or the most part, adverse effects have been demonstrated only for higher fields (e.g., greater than 15 kV/m) or longer exposure times than would occur for people residing near or working under transmission lines." If Intervenor disagrees with this conclusion, state with particularity tha basis for such disagreement, and identify all documents or persons upon which Intervenor relies in assessing the accuracy of this conclusion.

Answer _J4._Intervenor_does_not_ agree. and_as a basis for that disagreement refers to the New York Hearing Report earlier cited.

Interrogatory #5. In light of the NRC Staff's analysis of and conclusions regarding the environmental impacts of postulated accidents described in 5.9.4 of the FES, state with particularity the basis for Intervenor's conclusion in Contention 7 that "the potential that these facilities would have to be closed, either temporarily or pennanently, due to the release of substantial quantities of radioactive materials during an accident creates an unacceptable environmental impact."

Interrogatory f6. Identify the document (s) which or the person (s) whose opinion (s) provide (s) the basis for Intervenor's conclusion in Contention 7 that "the potential that these f acilities would have to be closed, either temporarily or permanently, due to the release of substantial quantities of radioactive materials during an accident creates an unacceptable environmental impact."

Interrogatory #7. Identify the levels of radioactive release which Intervenor contends would be of " substantial quantities" so as to require that the recreational facilities referenced in Contention 7 would have to be closed, temporarily or permanently.

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

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

Answer #5, 6, 7, 8, 9. Iritervenor has requested pennission to withdraw the contentions for which these interrogatories relate.

Interrogatory #10. Identify by name, title or position, and. address all persons Intervenor intends to present as witnesses to testify.with regard to Contentions 1 and 7.

Answer #10. Dr. Alwyn Scott, Professor, Department of Electrical and Computer-Engtnewing, University-of-Arizona;-Tucson;-Arizona. (Dr. Scott-in--

presently hospitalized with serious injuries and Intervenor may have to substitute another witness at a later time.) Dr. Ralph Armington, Professor, Illinois Institute of Technology, 3300 S. Federal, Chicago, IL 60616.

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

Answer fil. Lorraine Creek R. R. #1, Box 182 Manteno, IL 60950 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 the stated interrogatories. Copies of the reference documents were sent only to Applicant and NRC Staf .

Subscribed and sworn to befor C. Allen Bock me, a Notary Public, this 'Mg For the Intervenor Ttrem.

C. Allen Bock P.O. Box 342 Urbana, IL 61801-Express mail to:

C. Allen Bock 151 Bevier Hall 905 S. Goodwin Urbana, IL 61801

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .J;r,tig.

UShRc In the Matter of: ) I MY -3 gl :3 it )

COMMONWEALTH EDISON COMPANY )

) Docket Nos. 50-456 3

(Braidwo'od Nuclear Power ) 50-457 Office 00CMfi f[G[$hfffl Station, Units 1 and 2) ) BRANCH CERTIFICATE OF SERVICE I, C. Allen Bock, attorney for Intervenor, certify that copies of the Answers to Interrogatories 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.

.t/N~

C. Allen Bbck

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

SERVICE LIST

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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 Commission Office of the Secretary l Washington, DC 20555 Washington, DC 20555 1 Dr. Richard F. Cole Thomas J. Gordon, Esq.

Administrative Law Judge 206 N. Randolph Atomic Safety and Licensing Board Champaign, 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 l 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. Muclear 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 l 110 E. 'Adans Atanic Safety and Licensing Springfield, IL 62705 Appeal Board Panel U.S. Nuclear Regulatory Commission Rebecca J. Lauer (express mail)

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

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