ML19341A795

Response to NRC Second Second Set of Interrogatories Re S&W Evacuation Time Study.Prof Qualifications & Certificate of Svc Encl

ML19341A795
Person / Time
Site:	Zimmer
Issue date:	01/23/1981
From:	Weiss L CINCINNATI GAS & ELECTRIC CO., STONE & WEBSTER ENGINEERING CORP.
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19341A791	List: ML19341A790 ML19341A795
References
NUDOCS 8101280077
Download: ML19341A795 (21)

Text

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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 Power )

Station) )

4 AP P LI C AN"'S ' RESPONSES TO "NRC STAFF SECOND INTERROGATORIES TO APPLICANTS" j

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APPLICANIS' RESPON5ES 'IO "NRC SDFF SECOtO INIERROGMORIES 'IO APPLICAVIS" Itn. H. Zinner Nuclear Power Station, Unit No. 1 Docket No. 50-358 Interrogatory el i

Identify by inte.2Watcry number the names, addresses, place o#  !

empicyment ard positien therein, of all persens who answered, er l centributed to each such answer, excludir.g clerical persennel. i Restense All "NRC SM#" Secord Interrogatcries to Applicants" have been ars ered en behalf of the applicants by Mr. Iarry S. Weiss, Project Engineer of St ne & Webster Engineering Corpcration, 1ccated at 250 West 34th Street, New Ycrk, New Ycrk, 10119.

Interrocaterf 42 Set forth a statement of professicnal gmli#icaticns for each persen identified in answer to Inte22 e tory 1.

Besconse The professicnal g m14#icatiens are attached Pareto.

4 Inte.rrocaterf #3 Identify by name, address, place of employment arxi position therein, of all persens who centril:uted to the S&W Study, excluding clerical perscnnel.

Resoonse 24 followirg individuals at Stcra & Webster Engineering Corporation have centributed over 90 percent of the engineering effert associated with the S&W Study: Edward J. Siskin, Engineerig Manager; Jchn H. MacKinnen, Project.vauger; Iarry S. Weiss, Project Engineer; Jean L. McCluskey, Smic:

Environmen:a1 Engineer; Anthony M. Callendrello, Envirenme.taln Engineer:

?*e O Ieissing, Jr., Engineer - Envi w tal; and Steven L. Willins, n.7ineer - Pcw.r.

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- Interrogator! #4 Provide a statement of professional qmli#icatiens for each person identified in answer to Interrogaterf 3.

1 Reseense The professieral qualificaticns are attacPad bereto.

Interrocaterf 45 Identify spec 4ien11y ard in dew 1 the centributien to tra S&W Study :::ade by each person identified in answer to Interrogatory 3.

Rescense The S&W Study was perfc=ned under the directicn of Messrs. Edw.rd J.

Siskin, John H. MacKinnen, and Iarry S. Weiss. For that work Mr. Edward J. Siskin served as Engineering Manager, Mr. Jchn H. MacKirarn as Project Manager, and Mr. Iarry S. Weiss as Project Engineer. Primary responsi-bility for the administraticn, cocrdination and execution of the work was assigned to the Project Engineer. The other named individuals worked under the direct supervision of the Project Engineer in perfor: ting tasks necessary to the a::npletion of the S&W Study.

Interrocator/ 46 Identify in terms of trurs, the time spent en the S&W Study by each persen identified in answer to Interrogatory 3, specifying where these hours were spent, i.e., in New Ycrk City, in travel, in Fantuc./, W etc. ,

Rescense Acc:2nulated engineering hcurs spent directly attributed to preparaticn of the S&W Study include 415 hours0.0048 days <br />0.115 hours <br />6.861772e-4 weeks <br />1.579075e-4 months <br /> spent at Stone & Webster Engineering C ea-tien in New York City. Pricr to the preparaticn of this study, there were additional hours spent in New York City, Ken + 'cV f , and Chio relating to the radiological emergency planning efforts for the Zi:mer Staticn which aided in the prepmtien of the S&W Study. These tasks had been jn g y ess befcre the start of work en the S&W Study and inferration acquired during each of these efforts has been u*414'ed in the preparation of the S&W Study.

Beccrds of the accumulated hcurs worked on each task are not suff;ciently de*=iled to now separate the pcrtien of the hcurs sLWig the S&W Study, an individual's centributien to the S&W Study, ner the nature of that centri-  ;

buticn. It is therefere not pessible to spec 4"ic=11y attribute an exact  !

numt:er of hcurs spent en the S&W Study.  !

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Interrogatcry 47 Identify all State and l e l gover:2nent agencies contacted in making the S&W Study, setting forth the names of the persens centacted, the dates of the centact, and who, en behalf of the licensees, made such CCntact.

Respnse Telephcne centact by Stene and Webster was made with the follcwing State and local planning persennel in both Kentucky and Chio during the period of August 4, 1980 through August 18, 1980; the primary period of preparatien of the S&W Study.

1. Robert Alexander - F7hil Ccunty Gordinator Kentucky Disaster and Snergercy Serdces

2. Jchn Dixcn - Ke.ntucky Disaster and Energency Services

3. Charles Sogart - Kentucky Disaster and anergency Services

4. Kenneth Ccncver - Cle=cnt County Disaster Services Agerrf

5. Mfren Feinhardt - Caqtell County Superintendent of Transperaticn

6. Hertert Fitzer - A.J. Jolly Park, r 7N11 County, Kentucky

7. Bcbert Clark - Principal, Ncrther Elementary School, Butler, Kentucky

8. Delbert Feid - Kincaid Iake State Park, Pendleton County, Kentucky

9. Mr. !.cwe - Superintendent, Fa14"ity School, Felicity, Chio

10. Sgt. V. Pei.lly - Chio Naticnal GEM - Felicity Armory Interrccatory 48 Sumarize the subjects discussed ard the conclusions reached in al]

meetings with State and 1ccal gewa.e.nt agencies while preparing tra S&W Study.

Pesocrse Were were no meetings with State and local gcvernment agencies ccnducted during the prrA mtien of the S&W Study.

Interrocatory 49 Specify in detail the criteria and parameters which defira a "best estimate" as that term is used on S&W Study page 1-1, line 21. Set forth all assumptiens and judgments used in defining that *m.

Rescense The N *az 26, 1979 Nuclear Pegulatory h iMsien letter to Applicants i for Ccnstructicn Permits and Licenses of Plants Under Construction re-  !

questing "Infcz: nation PegarCN Evacuaticn Times" utilizes the term "best estimate" without specific definition. The letter requests both "best estimate" ard " adverse weather" estimates fer movement of the populatien.

In the absence of an NRC definitien, t's term "best estirate" was used in tra S&W Study to derrte times act adversely affected by weather conditions, u+4 ' 4 ?i7 the other assumptier.s specified in the study.

In w M atrr! #10 Identify all sMes and set forth all methodologies and calcula-tiens employed which resulted in the conclusien that the evacuation time of general populaticn in Zone I for adverse weather would be 10% lenger than the best estimatien evacuaticn time.

Respense Evacuation time estimater wre cbtained by adding the estimated noti-fication, nobilizaticn, and evacuation travel times. Notification times and ncbilizatien times are tre same in both best estimate and adverse weather ccnditions; evacuatien travel times for the :ene censisting of S m I were estimated by using a travel distance of twice the distance alcng the rcjer evacuaticn route frcm its inner: cst start to the edge of the evacuation =cne. A distance of 2.1 miles maximum was fcund to be the greatest distance to be traveled in Sector I. Twice this distance is 4.2 miles. An average vehicle speed of 25 mph was assumed for best  ;

estimate calculatiens; half that for adverse mather. Travel times 'ere then calculated as fc11cws:

Best estirate: 4.2 miles /25 nrh = 0.2 bcurs Adverse esticate: 4.2 miles /12.5 mph = 0.3 trurs Si ce nc'4"imtien times and acbilizatien times are the same, the 0.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> difference in travel time is also the difference between best esti-mate and adverse weather estimates. The 0.1 bcur is 10% of the 1 bcur best esticate evacuatien time for the cne censisting of Sector I.

Interrogatorv 411 Identify, ::ene by zene, in detail all physical and dowastic differences among the ::enes which caused the adverse weae.er general population evaca tion to vary frcm a 10% increase in Zone I for adverse weather as cppcsed to best estimate, to a 34% increase in Zenes I, III, VII for adverse weather as opposed to best estimate, and identify the specific cent:1butien of each identified difference to the increase in evacuaticn time aracng all of the adverse w_ather general pcpulation evacuaticn time estimates in Figure 3-1.

Besocnse Evacuatien time estirztes were cbtained by adding the estimated rctification, mcbili::atien, and evaw.ation travel times. For each ::ene, the evacuation travel time hears a different relationship to the estimated notificatien and mcbilizaticn time. Thus, when the evacuation travel time is increased by 100% to acccunt for adverse weather, the resulting percentage increase will be different for each evacuated area. The pcpulatien distribution in each

=cne, evacuation routes, and highway cracities wze used in de*ede.im evacuation travel times. Other than these factors, no specific physical differences in the zcnes wre censidered in determining the evacuaticn time estimates.

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Interrogatorv 412 Define arx1 quantify "Particularly severe winter weather corditions er severe flooding" as these terms are used en lines 39 and 40, page 1-2 S&W Study and quantitatively identify the differences between the terms quoted above and " adverse mather" as used is Figure 3-1.

Rescense The Nuclear Regulaterf Ccmnission letter to Applicants for Constmcticn Permits and Licensees of Plants Under Construction dated Da am%r 26, 1979 utilized but did not attspt to give any definition of the term " adverse mather." The S&W Study acccunts for " adverse wather" 'ef reducing highway capacities'cr average vehicle speeds. Page 5-7, lines 39 through 42 of the S&W St2/ state that:

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" Highway capacities and average vehicle speeds for adverse weather are censidered to be reduced by ene-half. This...acccunts for usual adverse w ather delays due to rain, light sncw, icing, and minor flooding."

I Therefore, as used in the S&W Study, "Particularly severe winter w ather conditions or severe flooding" refers to ecnditions wnich cause greater reductions than one-ba M in either highway capacities er average vehicle speeds. The trea m t of " adverse weather" in the S&W Study is in acccrdance with "An Evacuation Time Assessment of Nine Nuclear Power Plants Snergency Planning Zcnes, Volume 1, Program Report, Prepared for Federal h.gucy Maragement Agency, Wilbur Smith and Associates, June 1980." Regarding particularly severe winter weather, the repcrt states en page 24 lires 20 thrcugh 25, that in scme emergencf planning zones:

... disabling weather ccnditiens ocer every five to six years when traffic may not mcve for several days. These occurrences were censidered as exceptiens to the evacuation time assessment, because of the verf small and alrest insignificant prr+Aility of the siruitanecus ocer-rence of both an evacuatien warning and a snewfall occurring during the same days."

Interrocaterv #13 Set forth the criteria and garameters which define " adverse weather" as those terres are used in Figure 3-1 S&W Study.

Pescense See respense to In+=> w atery #12.

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Interrocatorv 414 Identify by route ntuber and mrber of persens the routes and population referred to in lines 41 and 42 cn page 1-2 S&W SeMy.

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Table 5-1 presents designated majcr evacuatien routes. In each zene, a ntuber of alternative routes are given by the table. The "part of the affected pcpulaticn (that) may already have been evacuated" refers generally to these **to ray have been affected by ficoding and have deparmd the area, but no attengt to specifically identify such persens had been made as part of the S&W SeMy.

In*a m aterv 415 Cescribe the methodology, calculaticns and analysis which are the basis of the S&W Study statement that "a nc=ber of alternative evacuatien rcutes are generally avmlable and a part of the affected

cpulaticn may already have been evacuated" (S&W Sedy, page 1-2, liras 39-43).

l Pas:ctse See respense to Interrogaterf #14.

Interrocator! #16 Zone by zene - identify all physical and da:cgraphic features which cause adverse weather evacuation times to be 5 to 25% higher without a suuet notificatien system while 10 to 35% higher (S&W SeMy, pp.1.2 ard 3.1) with a pr:rst notification. Ycur arser sbruld acccunt for the differences in the increased evacuatien time.

Besocrse Estimated evacuation travel tres are unaffected by whether a suaec notifi-caticn systen is in place. This is raadily apparent in Table 3-1. For example, fcr the zone c:2nposed of Sectors II, VI, and X, the adverse weather evacuation time without a su+L notificat. ten system, 4.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, is 0.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> aheve the best estimate time of 3.6 Irurs just as for that same zene the adverse weather time with a s u yL notificaticn system, 3.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, is also 0.8 hcurs above the 2.6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> best esti: nata. The difference in m entage increase is due to the icwr best estirate evacuatien time with a pranpt notification system coraidaved, which gives the inc:reased gentages when canpared in the manner used.

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9 Interrogater/ 4.7 Identify in detail the parameters of adverse weatbar assumed by the State and 1ccal planners listed in the S&W StMy (bottcm of p. 3-1) and centrast them with the parameters assumed in the S&W Study (S&W Study, p. 3-2, lines 9 and 10).

Pescense

As noted in lines 11 and 12 of page 3-2 of the S&W Study, "Tra assmpciens of State and local planners were nct included with trak resrJ.ts. " Scme idea of their considerations is, Irwever, available in the results forard' by CG&E's subnittal of August 1,1980 of the evacuation time estimates pre-pared by Kentucky Disaster and anergency Services, tra Clerment County Disaster Ser/ ice Agency (C"DSA), and Chio Disaster Services Agency (CCSA) .

For CCSA estirates for Clerrent County, the suhnit*al refers to adverse conditiens as " poor weather" in line 23 cf page 2 of the enciesure to their March 21, 1980 forerding letter. Cn page 3 of the enclosure, under a "Special Preblems" category, scme further elaborat:c.n is prended:

" Flooding along the Chio River occurs annually to scme degree but usually every 3 to 5 years it rises high encugh to cbstract traffic along U.S. Route 52 and requires scrne evacuation of New Richncnd and areas directly adjacent to the River.

"If evacuation should be required during a time of flooding, then the only routes open uculd be toward the west, thus, greatly hampering and slowing the evacuation process as shown by scme of our estimates for adverse conditions."

The Kentucky Disaster arxi Emergency Services time estimates for Bracken, Pendleton, and Campbell counties refer to an " adverse estimate" on the bar graph previc*M. No specific definiticn is prended for this estinte. A reference to " severe winter weather" is provided en page 2, lira 4 of the enc 1csure to tFa k forwarding letter to CG&E of March 21, 1980. The enclosure states en page 2, liras 4, 5, 11, 12 and 13: "most routes would be i:nPmble. ... icy conditiens wculd prevent many vehic frcm tra-versing the evacuaticn rcutes." Fcr Campbell Ccunty en pa w 3, lines 8 and 9 states: "In several places, high water (58 feet) along the Chio River ficcds FYS." Also, lirms 10 and 11 state "Several creeks f1 cod in the Gubser Mill area which could cause the use of alternate routes." The statement of methodology in the Kentucky Disas*ar and Emergency Ser71ces let*ar provides no infer: nation en how adverse weather was considered in that document.

. The CCDSA letter of April 1,1980 refers to " adverse poor weather" in the table prcvided for presentaticn of esti: nates. No further elabcraticn

, is prended. As noted in the S&W Study, en page 3-2, lines 13 thrcugh 17:

"Fmn inquiry with m, it was determined that *h.ir assumpticn for adverse weather included a 6 inch snewfall with ficcding. Severe condi-tiens such as these w:uld likely result in grea*ar reductions in ..A capacities and average vehicle speeds than were asstrned in this study."

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Interrocatorf 418 The S&W Stdy asstred adverse wather muld reduce road capacity and speeds by 50% (S&W Study, p. 3-2, line 11) yet evacuation time was increased 10 to 35% (S&W Study, p. 3-2, line 20) . ?qlain the rationale for your ccnclusion. I Restense See resp:nse to Interrocatory #10.

Interrocater/ 419 j Have the Applicants er any cne en their be W # pric: to Aucust 1980 ernpi-ically verified that adverse weather muld reduce read sped and capacity by 50% (S&W Study, p. 3-2) .

Resocnse No. See the response to Inteu- w atery #12.

Interrocaterv 420 Do the Applicants kncw of any snpirical verification of the 50%

reduction in road speed and capacity assumed to cccur in adverse mather?

Rescense See resp:rse to Inte-wtcrf #19.

Interrogatorf 421 If the resp:nse to Interrogatories 19 ard/cr 20 is affi= native, fully set forth that sugirical verification in detail.

Bescense See response to Inte2-wator/ #19.

Interrocaterv 422 Have 9a Applicants cr t.ny cne en r t'ai- ben 1# egirim'ly verified that evacuaticn ti:neu vculd increase 10 to 35% in adverse wa9.er (S&W Stcdy, p. 3-1) .

Besconse No. See respcnses to Interrogatories #10 ard #19, Interrocator/ 423 Do the Applicants knew of any sapirical verificaticn of the asser'ad 10 to 35% increase in evacuation time during adverse mather (S&W Study, p. 3-1).

Besocnse No. See respcnses to Interroga*aies #10 ard #19.

Interrogaterv 424 If the resp:nse to Interrogatories 22 ard 23 is affirrative, fully set fcrth, ::cne by zerm, that expirical verificatien in demi 1 Fe.crense No respense required.

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Interrogator / 42S Foot: note 3 to Table 5-1, page 5-11, S&W Study, i:xiicates that evacuation rcute average capacitf in vehicles per hour was derived frtxn reference 3 and reference 5. Explain hcw the capacities in Table 5-1 are so derived; cite by page and line ntster the use made of reference 3 and reference 5; include your methodology; include ycur calculatiens; include your assumetiens; and describe pur field 'crk.

Resocnse Table 5-1 of the S&W Study states that the Average Capacity for all of th two-lane roads is 1,000 vehicles per hcur. This capacity was cbtained fran the Highway Cacacity Manual (Faference 5) Table 10.7, Page 302-3.

A level of service E was utilized to deter:nine the capacity. That table lists a capacity of 2,000 vehicles per hcur total in both directions for a two-lane, t e ray road. For cne lane in one direction, half of that capacity, or 1,000 vehicles per hour, was used. The Trarpaticn and Traffic Engineering Handbock (Reference 3), Page 331, Table 8.1 provides the same information ard references the Eighway Capacity Manual.

':ne .c fcur-lane highways listed in Table 5-1 of the S&W Study are indi-cated to have capacities of 1,500 vehicles per hcur. This was a censervative estimate of the c'racity of two lanes of a four-lane highway based on the 1,000 vehicles per hour per lane capacity referenced above. Twice the single lane capacity was reduced fran 2,000 to 1,500 vehicles per hour to add censervatism to the capacity estimates.

Interrocaterv 426 Provide a descdption, including all assumptiens, calculatiens and field work, in detail of how the S&W Study cencluded that CR743 and CR756 have an average c., rarity of 1,000 vehicles par 1rur under emergency evacuation circumstances. This inte_wtcrf relates to the S&W Study conclusicn set fcrth en Table 5-1, page 5-10, of the S&W Study.

Rescense

! See regmw to Interrogatcry #25.

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EDUCATIONAL AND P.NICNAL QCALIFICATICNS tarry S. Weiss Project Engineer Stone .& Webster Encimering Cor:cration My name is Larry S. Weiss. My business address is Stone & Webster W naaring Corporation, 250 West 34th Street, New York, New York 10119.

I am Project Engineer reanenaible for all radiological mi=&g=cf planning in Stone & Webster's New York office. This positicn involves the direction of ernergency planning effer*a for three states, seven counties and many municipalities, preparatien of station esnergency plans, including the emer-gency plan for the Zimer Nuclear Pcwer Station.

I graduated fran Cocper Unicn with a B.E. in Mechanical Engineering and frczn Carnegie Mellen University with a M.S. in Machanical Engineering.

I also graduated fran the Naval Reacter's Nuclear Power School which is equivalent to a M.S. in nuclear engineering.

Prior to my employment at Stone & Webster, I was affiliated with the Westinghouse-Bettis Atcznic Power Laboratory as Superv'seri of Plant Engineering.

In that c=I= city, I was responsible for nuclear cperating, maintenance and test r, '. res for a number of classes of =*==+a reactor plants. Mdi-tional responsibilities in* Mad develegnent of emergency core cooling system operating swedures, resolution of cperating problems and inme=1 ccew.2ences and evaluaticn of the mI a* dant. I also served as a Senior NSSS technical field representative. In this positicn I was respcnsible for the safe Mv-t of sdmarine nuclear powr plant ref':elings, overhauls and test s w ams. In this positicn I was a gnali#ied radiation worker, parti.cipated in radiological emergency and nuclear accident c===1ty control drd.11s. I joined Stone & Webster Engineering Corporation in March 1980 as a Consultant in the Power Divisien. I have attended a workshcp on state and local govern-ment ernergency respense plans and sq=.oiess for crrrmercial fi:ced nuclear facili ties. I have been extensively involved in emergency planning efforts for nuclear power facilities and related state and local emergeccy planning efforts and s y ru.i. thereof.

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EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS Edvard J. Siskin Engineering Manager Stone & Webster Engineering Corporation l

My name is Edward J. Siskin. I am Manager of the Engineering Department.

My business address is Stone & Webster Engineering Corporation, 250 West 34th Street, New York, New York 10119. In this position, one of my tasks is supervision of the emergency planning efforts for the Zimmer Nuclear Power Station.

I graduated from the University of Pennsylvania with a B.S. in Electrical Engineering in 1963. I completed the Westinghouse-Bettis Atomic Power Laboratory Reactor Engineering School with distinction in 1965. This courss is equivalent to a M.S. in nuclear engineering. I completed training with the U.S. Atomic Energy Comnission relating to the operation of a Naval nuclear propulsion plant and have taken graduate courses in electrical engineering and mathematics at George Washington University and the Univer-sity of Pittsburgh.

Prior to joining Stone & Webster, I served 14 years with the Naval Reactors Division of the U.S. Atomic Energy Commission and its successor agencies. I have had experience in all aspects of design, construction and testing of the Navy's pressurized nuclear power plants. I have been involved i with various facets of nuclear emergency planning for approximately 10 years.

I was responsible for developing the emergency plan which was adopted as the Navy's standard. I was also extensively involved in the planning and conduct of drills conducted to verify the efficacy of these plans. I assisted in the review, for the Atomic Energy Commission, of the State of Connecticut's plan relating to General Dynamic's Electric Boat Division shipyard at Groton, Connecticut.

During my employment at Stone & Webster, I have had various assignments related to the design and construction of nuclear power stations. I have been involved in various facets of planning relating to a number of states and many local jurisdictions.

I am a member of the Institute of Electrical and Electronic Engineers and a member of the Atomic Industrial Forum. I have served as Chairman of the Subcomittee on engineering techniques for reducing occupational

{ exposures for that occupation.

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EDUCATIONAL AND PROFESSIONAL QUALIFICATION John H. MacKinnon l Project Manager Stone & Webster Engineering Corporation l l

i My name is John H. MacKinnon. My business address is Stone & Webster Engineering Corporation, 250 West 34th Street, New York, New York 10119.  !

I am Project Manager responsible for Wm. H. Zimmer Nuclear Power Station )

radiological emergency planning in Stone & Webster's New York office. In )

this position, I participated in emergency planning efforts for the Zimmer Nuclear Power Station, including the development of the evacuation study.

I graduated from the U.S. Naval Academy with a 3.S. in General Engineering. I attended Boston University's M3A program in 1979 and 1980.

While in the U.S. Navy, I took courses in technical, operational and managerial areas including submarines and nuclear propulsion. From 1958 to 1978, I was an officer in the U.S. Navy assigned to various positions related to the operation, maintenance, construction, testing, and quality control of ships, conventional submarines and nuclear submarines. During my tenure in the U.S. Navy, I have been engineering officer of a nuclear powered submarine. I have been responsible for preparation of operators for reactor safeguards examination by the Atomic Energy Conmission, was an Executive Officer of a nuclear attack submarine, war Commanding Officer of a nuclear-powered ballistic missile submarine and was a deputy squadron commander of a submarine squadron. In the last position, I was responsible for the establishment of Emergency Command Center at the U.S. Naval Submarine Base, New London, Connecticut, development of emersecry operating procedures for that facility and conducted in-depth drills and exercises utilizing the Emergency Command Center.

I joined Stone & Webster Engineering Corporation in 1978 and have been responsible for various projects related to engineering and designs in upgrade of a nuclear power plant emergency response planning and indus-trial security for nuclear power plants. I was also responsible for quality assurance auditing of projects and construction sites.

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EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS Jean L. McCluskey Technical Advisor Stone & Webster Engineering Cornoration l

4 My name is Jean L. McCluskey. My business address is now Stone & Webster Engineering Corporation, 245 Summer Street, Boston, Massachusetts 02107.

I am an environmental engineer in the Environmental Engineering Division of Stone & Webster. In this position I participated in the emergency planning efforts for the Zimmer Nuclear Power Station, including the development of the evacuation study.

I graduated from Northeastern University with a Bachelor of Science in Civil Engineering. I also obtained a Masters of Urban Aifairs from Boston Cniversity and have taken various technical courses and seminars since that time, including a Federal Interagency Radiological Emergency Response Planning Course.

Prior to my association with Stone & Webster Engineering Corporation, I held the position of Project Planner / Engineer in the Enviro Energy Division of Metcalf & Eddy, Inc. and Senior Environmental Project Engit;er for Exxon Company, U.S.A. My activities during these assignments included assignments related to civil engineering and analysis of environmental impacts associated with various projects.

During my employment with Stone & Webster Engineering Corporation,

=y responsibilities have included the administration and coordination of the efforts of teams of engineers, scientists and planners relating to comprehensive state radiological emergency response plans for two states and included development of site specific plans for four nuclear power plant sites and evacuation studies for five nuclear power plant sites.

I an a registered Professional Engineer in the States of Maine and New York.

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. EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS Anthony M. Callendrello Environmental Engineer Stone & Webster Engineering Corporation 1

My name is Anthony M. Callendrello. My business address is Stone & Webster i Engineering Corporation, 250 West 34th Street, New York, New York 10119. As au l

environmental engineer, I participated in certain portions of the emergency plan-ning efforts for the Zimmer Nuclear Power Station including calculations associ-ated with the evacuation study.

I graduated with a Bachelor of Engineering from Stevens Institute of Technol-ogy. I also received a Master of Engineering degree from the same ins titution Prior to joining Stone & Webster, I was employed by Lewis S. Goodfriend & Associ-ates, and Donely, Miller & Nowikas, Inc. I was responsible for projects involving industrial noise control for a number of industries. During my employment with Stone & Webster, I have been responsible for the technical review and coordination and direction relating to the preparation of radiological emergency plans for the state and counties in the vicinity of a nuclear facility. I directed efforts relating to the preparation of implementing procedures and training materials for state and local organizations.

I am a member of the American Society of Mechanical Engineers and the Nation-al Society of Professional Engineers. I am a Professional Engineer in the State of New Jersey.

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EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS Theodore O. Leissing Engineer - Environmental Stone & Webster Engineering Corocration lty name is Theodore O. Leissing. My business address is Stone & Webster Engineering Corporation, 250 West 34th Street, New York, New York 10119.

As an environmental engineer, I participated in various aspects of the radiological emergency preparedness planning for the Zi:mner Nuclear Power Station. I graduated from the New Jersey Institute of Technology with a B.S. in Environmental Engineering. Prior to joining Stone & Webster, I worked as a Graduate Research Assistant at the New Jersey _ Institute of Technology in air pollution research and air quality e,Jnitoring. In ad- '

dicion, I worked as a laboratory technician in water quality analysis.

EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS Steven L. Willins Engineer - Power Stone & Webster Engineering Cornoration My name is Steven L. Willins. My business address is Stone & Webster Engineering Corporation, 250 West 34th Street, New York, New York 10119.

I am an Engineer in the Power Division with Stone & Webster. In this position I assisted in the emergency planning efforts for the Zimmer Nuclear Power Station.

I graduated from Columbia University School of Engineering and Applied Science with a B.S. in Mechanical Engineering. Prior to joining Stone &

Webster, I was employed as a Summer Engineer Trainee wit's The Cincinnati Gas & Electric Company in the Mechanical Engineering Fossil Fuel Department.

l VERIFICATION STATE OF NEW YORK )

) SS COUNTY OF NEW YORK )

Larry S. Weiss, being first duly sworn, states that he is Project Engineer, Stone and Webster Engineering Corporation, 250 West 34th Street, New York, Nev York 10119, that he has read the contents of " Applicants' Response to NRC Starf's Second Interrogatories to Applicants"; and that the statements contained therein are true and correct to the best of his infor-1 mation, knowledge and belief.

.1- 9./f &~a "Larr'gs. Weiss STATE OF 44.) )SS:

COUNTY OF T zdd/ M )

1 Subscribed and sworn to before mq on this #J M day of (leum 19 g/ .

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CLAIR! P. GI'.'STINO NCTARY PUfJC, S: s :' New Y:rk No. 30 :D7709 Ou::32: .a %:rs ; C:unty Carr. Fi'e1 n Nes York C:unty Canun.cn Ia.;:.res t.'.crm Jo, 038

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

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The Cincinnati Gas & Electric ) Decket No. 50-358 l

Company, et al. )

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(William H. ::inmer Nuclear Pcwer )

! Station) )

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CIRTIFICATE CF SERVICE i

I hereby certify that ccpies of " Applicants ' Responses l

' to 'NRC Staf f Second Interrogatories to Applicants , '" dated January 23, 1981, in the captioned =acter, were served upcn  ;

the follcwing by deposit in the United States = ail this i 23rd day of January, 1931: t Charles 3echhcefer, Esq. Michael C. Farrar, Esq.

Chairman, A amic Safety Atomic Safety and Licensing and Licensing Scard Appeal 3 card U.S. Nuclear Regulatory U.S. Nuclear Regula:Or'f Ccmmission Ccmmission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Frank F. Ecoper, Member Chairman, Atomic Safety and Atcmic Saferf and Licensing Licensing Appeal Scard Panel Scard U.S. Nuclear Regulatory School of Natural Resources Ccmmission University of Michigan Washington, D.C. 20555 Ann Arbor, Michigan 48109 Mr. Glenn O. 3right, Member Chairman, Atcmic Safety and Licensing Scard Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Ccemission U.S. Nuclear Regulatory Washington, D.C. 20535 Ccmmission Washington, D.C. 20555 Charles A. Barth, Esq.

Richard S. Salzman, Esq. Counsel for the NRC Staff Chairmm, Atcmic Safety and Office of the Executive Legal Director Licensing Appeal Scard U.S. Nuclear Regulatory U.S. Nuclear Regulatory Ccmmissicn Ccmmission

• Washington, D.C. 20535 Washington, D.C. 20555 William J. Meran, Esq.

Dr. Lawrence R. Quarles General Counsel Atomic Safety and Licensing Cincinnati Gas & Electric Appeal Scard -

- Ccmpany U.S. Nuclear Regulatory Post Office Sex 960 Ccmmission Cincinnati, Ohio 45201 Washington, D.C. 20555

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1 Mr. Chase R. Stephens James H. Feldman, Jr., Esq.

Docketing and Service Branch 216 East Ninth Street Office of the Secretary Cincinnati, Ohio 45202 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John D. Woliver, Esq.

Clermont County Community William Peter Heile, Esq. Council Assistant City Solicitor Box 181 City of Cincinnati Batavia, Ohio 45103 Box 214 Cincinnati, Ohio 45202 David K. Martin, Esq.

Assistant Attorney General Mrs. Mary Reder Acting Director Box 270 Division of Environmental Law Route 2 Office of Attorney General California, Kentucky 41007 209 St. Clair Street Frankfort, Kentucky 40601 Andrew B. Denniscn, Esq.

Attorney at Law Robert A. Jones 200 Main Street Prosecuting Attorney of Batavia, Ohio 45103 Clermont County, Chic 154 Main Street Batavia. Ohio 45103

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Mark J. Wetterhahn ~

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