ML20148J633

Forwards Responses to Interrogatories M1-M4,L1-L11 & 01-011 Propounded by NRC to Lehigh Portland Cement.H1-H11 Will Be Sent Later

ML20148J633
Person / Time
Site:	Green County
Issue date:	10/27/1978
From:	White A DEGRAFF, FOY, CONWAY & HOLT-HARRIS
To:	Harding V NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 7811160048
Download: ML20148J633 (17)

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U. S. Nuclear Regulatory Commission A Washington, D. C. 20555 My Attention: Greene County Nuclear Power Plant Section Re: NRC Docket No. 50-549

Dear Ms. Harding:

. Enclosed herewith are our responses to-Interrogatories M1 through M4, L1 through L11, and 01 through 011 propounded by the Nuclear Regulatory Commission Staff to Lehigh Portland Cement Company. I have not' enclosed responses to Interrogatories H1 through H11 as I have not yet received those documents from Heidelberg,. Germany.

Very truly yours, DeGRAFF, F0Y, CONWAY & HOLT-HARRIS t

Algi d F. White, Jr.

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t GREENE COUNTY NUCLEAR POWER PLANT

' APPLICATION TO THE NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE OF. ENVIRONMENTAL. COMPATIBILITY t

INTERROGATORY:NO. . M1 '

REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF L DATED:. September 2'2, 1978' INTERROGATORY:

What is Lehigh's approximate share of the Northeast cement market for each of the 1.sst three years?

RESPONSE: 1 I

Lehigh's approximate share of the Northeast cement market for aach

, of the last three years is 15%.

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GREENE COUNTY NUCLEAR POWER PLANT

- APPLICATION TO THE NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE OF ENVIRONMENTA"L COMPATIBILITY INTERROGATORY NO. M2

' REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978 INTERROGATORY:

What percentage of Lehigh's national cement sales does its Northeast sales comprise for each of the last three years?

RESPONSE

The percentage of Lehigh's national cement sales which are Northeast region sales is approximately 127..  ;

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GREENE C0'UNTY NUCLEAR POWER PLANT APPLICATION TO THE NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE OF ENVIRONMENTAL COMPATIBILITY INTERROGATORY No. M3 REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978 INTERROGATORY:

What percentage of Lehigh's national cement earnings does its Northeast earnings comprise for each of the past three years?

RESPONSE

Lehigh's Northeast region did not contribute significantly to Lehigh's national cement earnings in the past three years.

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GREENE COUNTY NUCLIAL POWER PLANT. .

APPLICATION TO-THE NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING.AND THE ENVIRONMENT FOR A CERTIFICATE OF. ENVIRONMENTAL COMPATIBILITY I

INTERROGATORY NO..M4

. REQUESTED BY: NUCLEAR REGULAT011Y COMMISSION STAFF

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i DATED: Sep t ember . 22, '.19 78 ~

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-INTERROGATORY:

What relationship.does Lehigh's Northeast market performance have to Lehigh's overall market viability?--

RESPONSE

Lehigh's Northeast market performance has an important relationship to Lehigh's overall.. market viability-because it is Lehigh's goal to remain a national cement. pro'ducer having no less than 5 operating

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cement plants located throughout the United States. l

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GREENE COUNTY NUCLEAR POWER PLANT APPLICATION TO THE NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR' A CERTIFICATE OF ENVIRONMENTAL COMPATIBILITY INTERROGATORY NO. L1 REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978 INTERROGATORY:

Has the Lehigh board of directors given any consideration either in.

formal or informal proceedings to the loss of its facilities at Cementon as a result of the construction of the Greene County Nuclear Plant (GCNP) at the Cementon site? ,

RESPONSE

The Lehigh Board of Directors has given extensive consideration to the loss of its facilities at Cementon as a result of the construction of the Greene County Nuclear Plant at the Cementon site.

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GREENE COUNTY. NUCLEAR POWER PLANT APPLICATION TO THE NEW YORK STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE OF ENVIRONMENTAL COMPATIBILITY INTERROGATORY NO. L2 REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978 INTERROGATORY:

In the event that the GCNP is built on Lehigh property at Cementon, has the Lehigh board of directors determined either formally or in-formally that its production facilities at Cementon must be closed  !

permanently?

RESPONSE

The Lehigh Board of Directors has not formally determined that in the i event that the GCNP is built on Lehigh property at Cementon that its l production facilities at Cementon must be closed permanently. The  ;

subject of the intrusion of the GCNP on operations of the. Lehigh  !

-plant at Cementon has been extensively discussed and the Lehigh Board (

is convinc.ed that the disruptions caused by the construction of the GCNP-at Cementon will be such that they significantly impact the Lehigh production facility and will probably cause its premature closing, i Moreover, the construction of the GCNP on Lehigh property at Cementon l will deprive Lehigh of its site for a new low cost production facility which will'be necessary in the foreseeable future.

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INTERROGATORY No. L3 l

REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978

' INTERROGATORY:

In the' event that the GCNP is built on the Lehigh property, and that such a development causes the closing of the facility, has the Lehigh  !

board of directors given consideration either formally or informally j to what alternatives the company should take in response to this closing of its facilities?

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RESPONSE

I The Lehigh Board of Directors has given extensive informal considera-tion to what alternatives the company should take if the GCNP is built on Lehigh property in Cementon.

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GREENE COUNTY NUCLEAR POWER PLANT ,

APPLICATION:TO THE NEW YORK STATE BOARD ON'. ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE OF ENVIRONMENTAL COMPATIBILITY INTERROGATORY NO. L4 REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF  ;

DATED: September 22, 1978 J

INTERROGATORY:

' In the event of such a loss of the Cementon facilities, has the

- Lehigh board of directors either formally or informally determined that it is not feasible to construct.an entirely new facility at a virgin or "greenfield" site? ,

RESPONSE

The Lehigh Board of. Directors has informally determined that it is not feasible to construct an entirely new facility at a virgin or "greenfield" site located within the Northeast region.

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GREENE COUNTY NUCLEAR PO~WER PLANT LAPPLICATION TO THE NEW YORK STATE BOARD

.ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE 0F- ENVIRONMENTAL.. COMPATIBILITY INTERROGATORY No. L5 L

REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978 INTERROGATORY:

'Has'the Lehigh board of directors initiated or caused to be initiated c.

in.any way a search for a virgin or "greenfield" site? If so, in what governmental jurisdiction is the site located?

RESPONSE

The Lehigh Board of Directors has not initiated ~or caused to be initiated a search for a virgin or "greenfield" site within the North- ,

Least region. . Lehigh is considering a greenfield" plant in another

. area .of the United States. The construction-of a new cement plant on this "greenfield" site is not dependent;upon any contingencies affecting Lehigh's Cementon facilities. - Lehigh has initiated the preparation'of an environmental impact study preparatory to the con-struction offa new cement production facility located on land owned p by :Lehigh immediately adjacent to the Hudson: River at Cementon. ,

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. i APPLICATION.TO THE NEW YORK STATE BOARD ON ELECTRIC. GENERATION ~ SITING AND 'THE ENVIRONMENT-FOR A CERTIFICATE OF' ENVIRONMENTAL COMPATIBILITY  ;

INTERROGATORY NO. L6

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NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978 INTERROGATORY:

' In the event of a loss of-the Cementon facilities, has the Lehigh board of' directors.either formally or informally discussed _the <i feasibility of purchasing the existing (operating or non-operating) facilities of another cement manufa,cturer?

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RESPONSE

The Lehigh Board. of Directors has not discussed the feasibility of a purchasing the existing' facilities of another cement manufacturer in the Northeast. s AMufD EdwardW.Hylg

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- APPLICATION-TO THE NEW ' YORK- STATE BOARD ON ELECTRIC GENERATION, SITING AND THE. ENVIRONMENT l FOR A CERTIFICATE OF' ENVIRONMENTAL COMPATIBILITY INTERROGATORY NO. L7 REQUESTED BY:' .

' NUCLEAR REGULATORY COMMISSION STAFF DATED: Sept emb er' 22,-1978

' INTERROGATORY:

If such discussions have occurred, what candidates for such purchase have been identified, and where are they located?

RESPONSE

Not applicable. See answer to L6.

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GREENE COUNTY NUCLEAR ' POWER ' PLANT

- APPLICATION TO'THE NEW YORK STATE BOARD-.

ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE 0F ENVIRONMENTAL COMPATIBILITY L8, i INTERROGATORY NO.  ;

REQUESTED.BY: NUCLEAR REGULATORY. COMMISSION STAFF

> DATED:- September 22, 1978 l

INTERROGATORY:"

In the event of a loss'of.the Cementon facilities, has the Lehigh l board of directors' either . formally or informally _ discussed the

- feasibility of purchasing the adjoining. properties of the Alpha and/cr Marquette companies?' )

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RESPONSE

The Lehigh Board of Directors has not discussed .the feasibility of purchasing. the adjoining properties of 'the Alpha and/or Marquette '

companies,  ;

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, ~ APPLICATION TO THE NEW YORK'. STATE BOARD - '

ON ELECTRIC GENERATION SITING AND THE. ENVIRONMENT

. FOR A CERTIFICATE OF. ENVIRONMENTAL ~. COMPATIBILITY INTERROGATORY NO. L9.

REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF -

DATED: September 22,1978 -

INTERROGATORY: '

In the event of such-discussions, has the Lehigh board initiated or caused to = be initiated any. analysis of the feasibility of. a purchase

. of either the- adjoining Alpha or Marquette properties? ,

RESPONSE

'Not applicable.

See answer to L8.

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APPLICATION.TO<THE'NEW YORK. STATE BOARD

. ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT FOR A CERTIFICATE '0F ENVIRONMENTAL COMPATIBILITY ,

INTERROGATORY NO. L10l t

REQUESTED BY: NUCLEAR REGULATORY COMMISSION STAFF DATED: September 22, 1978 l 1

INTERROGATORY:

Has the Lehigh board of directors initiated. or caused to be initiated f eny direct or indirect, formal or informal contacts with Alpha-or t i

Marquette. officials regarding'a potential Lehigh purchase of either of' the companies adjoining properti.es? ..

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RESPONSE

Not applicable. See answer to L8.

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APPLICATION' TO THE NEW ~ YORK STATE BOARD *

- ON : ELECTRIC GENERATION . SITING' .AND THE ENVIRONMENT

,FOR A CERTIFICATE OF ' ENVIRONMENTAL COMPATIBILITY f

INTERROGATORY'NO. L11 lL REQUESTED BY: NUCLEAR REGULATORY' COMMISSION STAFF DATED: September 22,-1978 P 7

.-INTERROGATORY:

e In the event of'the above described loss of Lehigh's production facilities at Cementon, has the Lehigh board of directors formally.

i or ' informally' determined that a purchase of the adjoining properties of Alpha and/or Marquette is not fe'asible? On what basis was such c infeasibility established for each company's property?

RESPONSE

i The Lehigh Board of Directors made no determination with respect to the purchase of the adjoining properties of Alpha and/or Marquette.

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GREENE COUNTY NUCLEAR POWER PLANT APPLICATION TO THE'NEW YORK-STATE BOARD ON ELECTRIC GENERATION SITING AND THE ENVIRONMENT -l FOR A CERTIFICATE OF ENVIRONMENTAL COMPATIBILITY INTERROGATORY NO. 01 - 011 (Part IV)

NUCLEAR REGULATORY COMMISSION STAFF l REQUESTED BY:

DATED: September 22, 1978 Interrogatories Part IV, 01 through 011, are too vague to answer.

- The term " working group" is not a definitive term used within the Lehigh organization with the exception of references to the Executive Group. Executive Group discussions _of the matters inquired into in Interrogatories 01 through 011 are , covered in responses to interroga-tories L1 through Lil.

A ird F." White, Jr //

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