ML19261A279

Applicant'S Second Set of Interrogatories Propounded to Intervenor Miami Valley Power Project Pertaining to Contentions as Admitted as Issues by ASLB 760319 Order. Certificate of Svc Encl

ML19261A279
Person / Time
Site:	Zimmer
Issue date:	12/19/1978
From:	Wetterhahn M CONNER, MOORE & CORBER
To:
References
NUDOCS 7901020084
Download: ML19261A279 (12)

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Ag NUCLEAR REGULATORY COMMISSION b 9 os W In the Matter of )

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THE CINCINNATI GAS & ELECTRIC ) Docket No. 50-358 COMPANY, et al. )

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(Wm. H. Zimmer Nuclear Station) )

APPLICANT'S SECOND SET OF INTERROGATORIES TO MIAMI VALLEY POWER PROJECT Pursuant to 10 C.F.R. S2.740b of the Nuclear Regulatory Commission's Rules of Practice, Applicant, The Cincinnati Gas and Electric Company, by its attorneys, hereby propounds the following interrogatories to intervenor, Miami Valley Power Project, to be answered fully in writing, under oath, within fourteen (14) days after service hereof in accordance with the following definitions and instructions:

Definitions and Instructions

1. For each interrogatory, please state the full name, address, occupation and employer of each person answering the interrogatory and designate the interrogatory, or part thereof, he or she answered.

2. The following definitions shall apply:

(a) "Intervenor" or " Project" shall mean Miami Valley Power Project.

(b) " Person" shall mean an individual, person, corporation, proprietorship, partnership, or any other entity.

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(c) " Identification" or " identity," when re-ferring to an individual, corporation, or other entity, shall mean that intervenor shall set forth the name, present or last known address, and if a corporation or other entity, its principal place of business or if an individual, his or her title or titles and by whom employed. Once an individual, corporation, or other entity has been thus identified in answer to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation, or other entity to state merely his, her or its name.

(d) " Description" or " describe" when referring to a document as hereinafter defined, shall mean that the intervenor shall set forth the author or originator, addressee (s) , date, title and subject matter, the present custodian of any copy thereof and the last known address of each such custodian. In lieu of describing the document, intervenor may attach a copy thereof to its answers, indicating the question to which the attached document is intended to be responsive. If the information requested in this paragraph does not appear on the face of such attached document, then intervenor shall indicate that information for each document so attached.

(e) " Document" shall mean any written, printed, typed or any other graphic matter of any kind or nature, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, custody, or control of inter-venor, or its officials, employees, or agents; it shall also mean all copies of documents by whatsoever means made.

(f) "Date" shall mean exact day, month and year, if ascertainable, or, if not ascertainable, the best approximation (including the relation-ship to other events).

(g) "Zimmer Station" shall mean the Wm. H. Zimmer Nuclear Power Station.

3. These interrogatories request all knowledge or in-formation in intervenor's possession and/or knowledge and information in the possession of intervenor's agents, repre-sentatives, and, unless privileged, attorneys.

4. The following interrogatories apply to the contentions as admitted as issues in controversy in this proceeding by the Atomic Safety and Licensing Board's " Order Granting Petitions for Intervention and Providing for Hearing" dated March 19, 1976. The following interrogatories utilize the numbering system of the granted contentions contained in

" Applicants' Response to the November 16, 1978 Order of the Atomic Safety and Licensing Board" dated December 5, 1978, the relevant portion of which is attached.

Interrogatories

1. List the full name and address of each person who will represent, be a spokesman for, or conduct examination or cross examination of any witnesses during the course of this proceeding for the Project and his position with or relationship to the Project.

2. State the number of members the Project has at the present time.

3. Provide a list of the officers of the Project, indicating the office held by each.

4. With regard to Contention 11, specify and describe the " current data" what you rely upon to demonstrate "that there is no need for the Zimmer Station at this time because Dayton Power and Light's peak demand is not and will not be sufficient to justify the added power until after 1985."

Describe the source of this data.

5. With regard to Contention ll, has the Project es-timated the load growth of Dayton Power and Light Company

[ hereinafter "DP&L"] for the years 1978-1985? If so, describe and provide the projected peak loads for each year and all calculations and assumptions used in sach projections. If not, describe the projections of load growth for DP&L that the Project relies on as its basis for this contention.

State the measure of uncertainty which is present in the load growth projections made by or relied upon by the Project.

6. With regard to Contention 11, state the new capacity additions the Project considered available to DP&L for each

year between 1978 and 1985. Describe and provide the evaluation, study, calculations and/or investigation upon which these values are based.

7. With regard to Contention 11, state the values for necessary and predicted reserve reqJirements for DP&L for each year between 1978 and 1985 the Project utilized or has relied upon in support of this contention. Describe the source and basis for the reserve requirements utilized by the Project, including the methodology and all assumptions and calculations.

8. Identify the expert witnesses that the Project intends to call to testify on its behalf regarding Conten-tion 11. Provide a statement of each witness's professional qualifications and an outline of the facts and opinions to which he will testify.

9. With regard to Contention 12, if the Project has conducted or relies upon an evaluation, analysis, study, calculations and/or investigation regarding the number of U.S. commercial nuclear power generating stations and the total electrical output of such stations which will be competing for available uranium with the Zimmer Station, describe and provide the usage of uranium (in tons U 0 38 these U.S. commercial nuclear power generating stations predicted by such evaluation, analysis, study, calculation and/or investigation. Provide a breakdown of this usage on an annual basis (in tons U 38 0 ). Describe the methodology, all assumptions, calculations, including those regarding

years of operation of such units, and the capacity factor for each year of operation utilized.

10. With regard to Contention 12, if the Project has information requested by Interrogatory 9 for foreign or worldwide nuclear power generating stations, provide the information called for by Interrogatory 9 for these categories.

11. With regard to Contention 12, describe the uranium resources and the corresponding price per pound of U3 08 as-sumed, i.e., the total uranium available for use in U.S.

commercial nuclear power stations'(in tons U 03 8), which the Project relied upon in concluding that an adequate fuel supply would not be available, and describe the evaluation, analysis, study, calculation and/or investigation which is the basis for the Project's response to this interrogatory.

State what portion of such uranium resources are assumed to be U.S. reserves and what portion foreign.

12. With regard to Contention 12, state the level of exploration activity in the U.S. (in tons U3 0g) the Project utilized for the years 1980-2020 in evaluating the amount of uranium which would be available. Describe the evaluation, analysis, calculations and/or investigation which is the basis for the Project's response to this interrogatory.

13. With regard to Contention 12, describe the estimates of the price of uranium for the years 1980-2020 (in dollars per pound U 03 8) that the Project utilized in its projection of available fuel supply from U.S. sources. State what assumptions regarding price escalation the Project utilized

regarding the price of uranium for the years 1980-2020. If the Project has analyzed or relies upon an analysis of available resources as a function of price, describe such analysis and detail the methodology, all assumptions and calculations made.

14. With regard to Contention 12, state how the Project's analysis of uranium resources and utilization takes into account the uranium already purchased for the Zimmer Station.

15. Identify the expert witnesses that the Project intends to call to testify on its behalf regarding Conten-tion 12. Provide a statement of each witness's professional qualifications and an outline of the facts and opinions to be included in such testimony.

16. With regard to Contention 13, describe specifically the equipment used in the operation of the plant that the Project alleges will be " excessively costly." Describe spe-cifically each such piece of equipment, the Project's estimate of its cost, and its basis for such estimate and the cost for such piece of equipment utilized by the Cincinnati Gas and Electric Company (hereinafter " Company"), if known to the Project. Describe the sources of the Project's estimates and state any reasons of which the Project is aware for the differences in such estimates from the cost to the Company.

17. With regard to Contention 13, describe specifically the equipment used in the construction of the plant that the Project alleges will be " excessively costly." Describe spe-

cifically each such piece of equipment, the Project's estimate of its cost, and its basis for such estimate and the cost for such piece of equipment utilized by the Company, if known to the Project. Describe the sources of the Project's estimates and state any reasons of which the Project is aware for the differences in such estimates from the cost to the Company.

18. With regard to Contention 13, describe specifically each of the " escalating costs" associated with the operation of the Station referred to in that contention. Provide the estimate of each such cost made by the Project or upon which it relies, and the basis, assumptions, methodology and detailed calculations for such estimates. Describe the comparable estimates used by the Company, if known to the Project, and state the reasons of which the Project is aware for the difference in such estimates.

19. With regard to Contention 13, state and describe the revenue that you projected from the operation of the Station for each of its owners on an annual basic. Do the Project's estimates or the estimates upon which it relies take into account future rate increases? If your answer is in the affirmative, identify the timing and amount of rate increases assumed for each owner. If your answer is in the negative, state the specific reasons why rate increases were not assumed.

20. With regard to Contention 13, has the Project made any estimates, or does the Project rely on any estimates, of costs already sunk into the Zimmer Station and costs which must be expended to complete the Station? If so, describe such estimates, the basis for such estimates, and the dates on which the estimates were made or are based.

21. Identify the expert witnesses that the Project intends to call to testify on its behalf regarding Conten-tion 13. Provide a statement of each witness's professional qualifications and an outline of the facts and opinions to be included in such testimony.

Respectfully submitted, CONNER, MOORE & CORBER Mark J. Wetterhahn Counsel for the Applicants December 19, 1978

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MIAMI VALLEY POWER PROJECT (PROJECT)

11. Current data demonstrates that there is no need for the Zimmer plant at this time because Dayton Power and LightIs pdak demand is and will not be sufficient to justify the added power until after 1985.

12. The Project alleges that the Applicants cannot guarantee an adequate s'upply of nuclear fuel for the plant in question. The Board construes this allegation to be that Applicants will not have an adequate fuel supply to operate the plant which is sought to be authorized for operation.

13. The equipment used in the construction and operation of the plant will be excessively costly and, in effect, beyond the financial capability of Applicants.

Applicants are financial unqualified to operate the plant .

because of escalating costs.

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UNITED STATZS OF AMERICA NUCLEAR REGULATORY COMMISSION.

In the Matter of )

')

THE CINCINNATI GAS & ELECTRIC ) Docket No. 50-358 COMPANY, et al. )

)

(Wm. H. Zimmer Nuclear Power )

Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Second Set of Interrogatories to Miami Valley Power Project," dated December 19, 1978, in the captioned matter were served upon the following by deposit in the United States mail this 19th day of December, 1978:

Charles Bechhoefer, Esq. Dr. Lawrence R. Quarles Chairman, Atomic Safety Atomic Safety and Licensing and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Michael C. Farrar, Esq.

Dr. Frank F. Hooper, Member Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory School of Natural Resources Commission University of Michigan Washington, D.C. 20555 Ann Arbor, Michigan 48109 Chairman, Atomic Safety and Licensing Board Panel Mr. Glenn O. Bright, Member U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Chairman, Atomic Safety and Washington, DTC. ~'20555 .lcensing Appeal Board Panel U.S. Nuclear Regulatory Richard S. Salzman, Esq. Commission Chairman, Atomic Safety and Washington, D.C. 20555 Licensing Appeal Board U.S. Nuclear Regulatory Commission .

Washington, D.C. 20555

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Stephen M. Schinki, Esq. William Peter Heile, Esq.

Counsel for the NRC. Staff Assistant City Solicitor Office of the Executive City of Cincinnati Legal Director Box 214 U.-3. Nuclear Begulatory Cincinnati, Ohio 45202 Commissien Washington, D.C. 20555 Mr. Stephen Schumacher Miami Valley Power Project William J. Moran, Esq. Post Office Box 252 General Counsel Dayton, Ohio 45401 Cincinnati Gas & Electric Company John D. Woliver, Esq.

Post Office Box 960 Clermont County Community Cincinnati, Ohio 45201 Council Box 181' Mr. Chase R. Stephens Batavia, Ohio 45103 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 .

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.' 31 UNITED STATES OF AMERICA ,

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In the Matter of )

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TIIE CINCINNATI GAS & ELECTRIC ) Docket No. 50-358 COMPANY, et al. )

)

(Wm. H. Zimmer Nuclear Station) )

APPLICANT'S SECOND SET OF INTERROGATORIES TO MIAMI VALLEY POWER PROJECT Pursuant to 10 C.F.R. S2.740b of the Nuclear Regulatory Commission's Rules of Practice, Applicant, The Cincinnati Gas and Electric Company, by its attorneys, hereby propounds the following interrogatories to intervenor, Miami Valley Power Project, to be answered fully in writing, under oath, within fourteen (14) days after service hereof in accordance with the following definitions and instructions:

Definitions and Instructions

1. ior each interrogatory, please state the full name, address, occupation and employer of each person answering the inte'_rogatory and designate the interrogatory, or part thereof, he or she answered.

2. The following definitions shall apply:

(c) "Intervenor" or " Project" shall mean Miami Valley Power Project.

(b) " Person" shall mean an individual, person, corporation, proprietorship, partnership, or any other entity.

. (c) " Identification" or " identity," when re-ferring to an individual, corporation, or other entity, shall mean that intervenor shall set forth the name, present or last known address, and if a corporation or other entity, its principal place of business or if an individual, his or her title or titles and by whom employed. Once an individual, corporation, or other entity has been thus identified in answar to an interrogatory, it shall be sufficient thereafter when identifying that individual, corporation, or other entity to state cerely his, her or its name.

(d) " Description" or " describe" when referring to a document as hereinafter defined, shall mean that the intervenor shall set forth the author or originator, addressee (s) , date, title and subject matter, the present custodian of any copy thereof and the last known address of each such custodian. In lieu of describing the document, intervenor may attach a copy thereof to its answers, indicating the question to which the attached document is intended to be responsive. If the information requested in this paragraph does not appear on the face of such attached document, then intervenor shall indicate that information for each document so attached.

(e) " Document" shall mean any written, printed, typed or any other graphic matter of any kind or nature, and all mechanical and electronic sound recordings or transcripts thereof, in the possession, custody, or control of inter-venor, or its officials, employees, or agents; it shall also mean all copies of documents by whatsoever means made.

(f) "Date" shall mean exact day, month and year, if ascertainable, or, if not ascertainable, the best approximation (including the relation-ship to other events).

(g) "Zimmer Station" shall mean the Wm. H. Zimmer Nuclear Power Station.

3. These interrogatories request all knowledge or in-formation in intervenor's possession and/or knowledge and information in the possession of intervenor's agents, repre-sentatives, and, unless privileged, attorneys.

4. The following interrogatories apply to the contentions as admitted as issues in controversy in this proceeding by the Atomic Safety and Licensing Board's " Order Granting Petitions for Intervention and Providing for Hearing" dated March 19, 1976. The following interrogatories utilize the numbering system of the granted contentions contained in

" Applicants' Response to the November 16, 1978 Order of the Atomic Safety and Licensing Board" dated December 5, 1978, the relevant portion of which is attached.

_4_

Interrogatories

1. List the full name and address of each person who will represent, be a spokesman for, or conduct examination or cross examination of any witnesses during the course of this proceeding for the Project and his position with or relationship to the Project.

2. State the number of members the Project has at the present time.

3. Provide a list of the officers of the Project, indicating the office held by each.

4. With regard to Contention 11, specify and describe the " current data" that you rely upon to demonstrate "that there is no need for the Zimmer Station at this time because Dayton Power and Light's peak demand is not and will not be sufficient to justify the added power until after 1985."

Describe the source of this data.

5. With regard to Contention 11, has the Project es-timated the load growth of Dayton Power and Light Company (hereinafter "DP&L"] for the years 1978-1985? If so, describe and provide the projected peak loads for each year and all calculations and assumptions used in such projections. If not, describe the projections of load growth for DP&L that the Project relier on as its basis for this contention.

State the measure of uncertainty which is present in the load growth projections made by or relied upon by the Project.

6. With regard to Contention 11, state the new capacity additions the Project considered available to DP&L for each

year between 1978 and 1985. Describe and provide the evaluation, study, calculations and/or investigation upon which these values are based.

7. With regard to Contention 11, state the values for necessary and predicted reserve requirements for DP&L for each year between 1978 and 1985 the Project utilized or has relied upon in support of this contention. Describe the ,

source and basis for the reserve requirements utilized by the Project, including the methodology and all assumptions and calculations.

8. Identify the expert witnesses that the Project intends to call to testify on its behalf regarding Conten-tion 11. Provide a statement of each witness's professional qualifications and an outline of the facts and opinions to which he will testify.

9. With regard to Contention 12, if the Project has conducted or relies upon an evaluation, analysis, study, calculations and/or investigation regarding the number of U.S. commercial nuclear power generating stations and the total electrical output of such stations which will be competing for available uranium with the Zimmer Station, describe and provide the usage of uranium (in tons U 03 8) these U.S. commercial nuclear power generating stations predicted by such evaluation, analysis, study, calculation and/or investigation. Provide a breakdown of this usage on an annual basis (in tons U 03 g). Describe the methodology, all assumptions, calculations, including those regarding

years of operation of such units, and the capacity factor for each year of operation utilized.

10. With regard to Contention 12, if the Project has information requested by Interrogatory 9 for foreign or worldwide nuclear power generating stations, provide the information called for by Interrogatory 9 for these categories.

11. With regard to Contention 12, describe the uranium resources and the corresponding price per pound of U30 8 as-sumed, i.e._, the total uranium available for use in U.S.

commercial nuclear power stations (in tons U3 0g), which the Project relied upon in concluding that an adequate fuel supply would not be available, and describe the evaluation, analysis, study, calculation and/or investigation which ic the basis for the Project's response to this interrogatory.

State what portion of such uranium resources are assumed to be U.S. reserves and what portion foreign.

12. With regard to Contention 12, state the level of exploration activity in the U.S. (in tons U 03 0) the Project utilized for the years 1980-2020 in evaluating the amount of uranium which would be available. Describe the evaluation, analysis, calculations and/or investigation which is the basis for the Project's response to this interrogatory.

13. With regard to Contention 12, describe the estimates of the price of uranium for the years 1980-2020 (in dollars per pound U 03 8) that the Project utilized in its projection of available fuel supply frcm U.S. sources. State what assumptions regarding price escalation the Project utilized

regarding the price of uranium for the years 1980-2020. If the Project has analyzed or relies upon an analysis of available resources as a function of price, describe such analysis and detail the methodology, all assumptions and calculations made.

14. With regard to Contention 12, state how the Project's analysis of uranium resources and utilization takes into account the uranium already purchased for the Zimmer Station.

15. Identify the expert witnesses that the Project intends to call to testify on its behalf regarding Conten-tion 12. Provide a statement of each witness's professional qualifications and an outline of the facts and opinions to be included in such testimony.

16. With regard to Contention 13, describe specifically the equipment used in the operation of the plant that the Project alleges will be " excessive costly." Describe spe-cifically each such piece of equipment, the Project's estimate of its cost, and its basis for such estimate and the cost for such piece of equipment utilized by the Cincinnati Gas and Electric Company (hereinafter " Company"), if known to the Project. Describe the sources of the Project's estimates and state any reasons of which the Project is aware for the differences in such estimates from the cost to the Company.

17. With regard to Contention 13, describe specifically the equipment used in the construction of the plant that the Project alleges will be " excessively costly." Describe spe-

cificalPr each such piece of equipment, the Project's estimate of its cost, and its basis for such estimate and the cost for such piece of equipment utilized by the Company, if known to the Project. Describe the sources of the Project's estimates and state any reasons of which the Project is aware for the differences in such estimates from the cost to the Company.

18. With regard to Contention 13, describe specifically each of the " escalating costs" associated with the operation of the Station referred to in that contention. Provide the estimate of each such cost made by the Project or upon which it relies, and the basis, assumptions, methodology and detailed calculations for such estimates. Describe the comparable estimates used by the Company, if known to the Project, and state the reasons of which the Project la aware for the difference in such estimates.

19. With regard to Contention 13, state and describe the revenue that you projected from the operation of the Station for each of its owners on an annual basis. Do the Project's estimates or the estimates upon which it relies take into account future rate increases? If your answer is in the affirmative, identify the timing and amount of rate increases assumed for each owner. If your answer is in the negative, state the specific reasons why rate increases were not assumed.

20. With regard to Contention 13, has the Project made any estimates, or does the Project rely on any estimates, of costs already sunk into the Zimmer Station and costs which must be expended to complete the Station? If so, describe such estimates, the basis for such estimates, and the dates on which the estimates were made or are based.

21. Identify the expert witnesses that the Project intends to call to testify on its behalf regarding Conten-tion 13. Provide a statement of each witness's professional qualifications and an outline of the facts and opinions to be included in such testimony.

Respectfully submitted, CONNER, MOORE & CORBER

/ ]

Mark J. Wetterhahn Counsel for the Applicants December 19, 1978

e MIAMI VALLEY POWER PROJECT (PROJECT)

11. Current data demonstrates that there is no need for the Zimmer plant at this time because Dayton Power and Light Is p'eak demand is and will not be sufficient to justify the added power until after 1985.

12. The Project alleges that the Applicants cannot guarantee an adequate s'upply of nuclear fuel for the plant in question. The Board construes this allegation to be that Applicants will not have an adequate fuel supply to operate the plant which is sought to be authorized for operation.

13. The equipment used in the construction and ,

s operation of the plant will be excessively costly and, in effect, beyond the financial capability o#. Applicants.

Applicants are financial unqualified to operate the plant .

because of escalating costs.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

THE CINCINNATI GAS & ELECTRIC ) Docket No. 50-358 COMPANY, et al. )

)

(Wm. H. Zimmer Nuclear Power )

Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Second Set of Interrogatories to Miami Valley Power Project," dated December 19, 1978, in the captioned matter were served upon the following by deposit in the United States mail this 19th day of December, 1978:

Charles Bechhoefer, Esq. Dr. Lawrence R. Quarles Chairman, Atomic Safety Atomic Safety and Licensing and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Michael C. Farrar, Esq.

Dr. Frank F. Hooper, Member Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Schcul of Natural Resources Ccamission Uni ersity of Michigan Washington, D.C. 20555 Ann Arbor, Michigan 48109 Chairman, Atomic Safety and

-- - Licensing Board Panel Mr. Glenn O. Bright,_ Member U.S. Nuclear Regulatory Atcmic Safety and Licensing Ccemission

~

Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission ~~

Chairman, Atomic Safety and Washington, D.C. 20555 Licensing Appeal Board Panel

_ U.S. Nuclear Regulatory Richard S. Sal man, Esq. Cer:: mission Chairman, Atomic Safety and Washington, D.C. 20555 Licensing Appeal Board U.S. Nuclear Regulatory Ccmmission _ _ _ _ . .

_ _ _ _ _ _ _ Washington, D.C. 20555

Stephen M. Schinki, Esq. William Peter Heile, Esq.

Counsel for the NRC Staff Assistant City Solicitor Office of the Executive City of Cincinnati Legal Director Box 214 U.S. Nuclear Regulatory Cincinnati, Ohio 45202 Commission Washington, D.C. 20555 Mr. Stephen Schumacher Miami Valley Power Project William J. Moran, Esq. Post Office Box 252 General Counsel Dayton, Ohio 45401 Cincinnati Gas & Electric Company John D. Woliver, Esq.

Post Office Box 960 Clerment County Ccanunity Cincinnati, Ohio 45201 Council Box 181 Mr. Chase R. Stephens Batavia, Ohio 45103 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Ccmmission Washington, D.C. 20555 .

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