ML20032E080
| ML20032E080 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/12/1981 |
| From: | Dennison A DENNISON, A.B., ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8111190608 | |
| Download: ML20032E080 (65) | |
Text
.
OX "KETED
'3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY'AND LICENSING BOMD gN 16 P3'22 4Ao e OF SECRETARY John ". Frye, III, Chairman,,,mi;tiG & SERVICE M.
Stanley Livingston, Member BRANCH Frank F. Hooper, Member In the Matter of l
CINCINNATI GAS AND ELECTRIC :
DOCKET NO. 50-358 (William H.
Zimmer Nuclear APPLICATION FOR x
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Zimmer Area Citizens-Zimmer Area Citizens of Kentuc ~
ZAC-ZACK) sets forth its revised contentions pursuant to the Pre-herring Conference Order issued by the Board November 5, 1981.
i REVISED CONTENTIONS i
The authorities set forth in ZAC-ZACK's contentions as originally filec are incorporated herein and those portions of 10 C.F.R. and NUREG-0654, FEMA-> REP-1 cited as interim rules and regulation in the original contentions are hereby amended to incorporate those provisions in their final form.
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Authority for the _equirement that Brokin County, Ohio, be included into the emergency planning response of the plume exposure zone is as follows:
Brown County is situated from the approximately 10 and 1/8th miles generally east Zimmer Station; the current plume exposure zone depicted on emergency planning zone maps presented in local plans ter-minates the plume exposure EPZ at the Brown and Clermont counties border; the conditions of the topography and land characteristics placing the involved areas of Brown County in an elevation plane in-excesc of 400 feet above the Zimmer access routes for the affected Brown County population Station; are in part common for certain affected populations in Clermont County (particularly U.S.
52 and the population of Clermont County involved in Designated Sector SE (G), ESE(F) and involving an approximate Clermont County population of E (E) 2,518 [Clermont Plan, SII-I, at pp. II-I-17 and II-I-22] in 52 to which that affected population is routed from U.S.
S.R. 133 and subsequently alternate S.R. 222 and 232 [Clermont Plan SII-I, at p. II-I-18] requiring a greater distance and the condition travel time within the plume exposed area);
in Brown County there are no response needs, capabilities that or implementation of emergency resource personnel for an and 10 C.F.R.
emergency response to a Zimmer accident or event; S50.47 (c) (2), which provides, inter alia:
2
[g]enerally, the plume' exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles [16 km) in radius * * *
- The exact size and configuration of the EPZs surrounding a part-icular nuclear power reactor shall be determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries."
(Emphasis supplied by writer).
See also.10 C.F.R. 550.33(g) to the same effect.
Re vi s e d Contentions Presented.
20.
The evacuation plans and the emergency response capa-bilities for the plume exposure pathway of the Emergency Planning Zone consisting of, and involving, parts of'Clermont County and Brown County, Ohio, and Campbell County, Pendleton County and Bracken County, Kentucky, including the municipcl and village political subdivision: therein, are inadequate in their respective f ailures to timely and promptly evacuate the popula-tion within that rene to appropriately reduce, or minimize, radiation exposure for the protection of the safety and health of the public, due to:
a].
The absence of a local control site, or emergency operations center, in Brown County, Ohio,.as the emergency l
as well as the absence of any resource and command cente,
equipment or staff in Brown County responsible for controlling and directing the evacuation of the affected Brown County population and a portion of the Clermont County population, or in any manner directing, and altering as necessary, evacuation fire routes in Brown County and directing and deploying police, and para-medic personnel as emergency response personnel.
3 i
~
t Specificaily.
1].
"Se absence of any plan, county =or. state, which 2
addresses emergency response in Brown CountyLfor prcmpt I
notification of the populace affected to evacuate or to de-f termine. evacuation routes and related deployment of emergency resource personnel to support evacuation and render aid to the population as necessary.
[No plan is in existence}.
2].
The absence of any prompt warning system in Brown County to notify the pub 7 to take protective action, in-cluding evacuation, and subsequent information pertaining to protective action, including evacuation routes.
[No plan or equipment is in existence].
3].
The absence of a Disaster Service Agency - (and its 4
Director) in Brown County to create an emergen'cy preparedness plan and to coordinate, supervise and implement emergency preparedness and resources in the event of accidentor event at the Zimmer Station, to direct protective action, including evacuation and deployment of local emergency support groups to implement prompt and timely evacuation of the af fected population of Brown County and a portion of the Clermont County population; and the absence of an emergency operations center in Brown County properly equipped and staffed to protect the health and safety of the affected populace of Brown County.
[No plan, Disaster Service Agency, EOC or staff and equipment is in existence].
4
b].
The absence of adequate communication system, or systems, both telephone and radio, for the coordination and direction of evacuation and receipt and dissemination of data and information within any involved county, including Brown County, Ohio, for communications between the respective county EOC and the emergency response support groups and between personnel of the emergency response support groups.-
Specifically.
1].
The absence of any radio facility in Brown County, Ohio, capable of receipt and transmission of messages between Brown County and its emergency response support groups, i.e.,
police, fire, para-medic and special concerns (nursing homes, schools, parks) and between Brown County and the counties of Clermont, Ohio, and Campbell, Pendleton and Bracken, Kentucky EOCs, the Ohio and Kentucky state EOCs and the applicants' EOF.
[No plan provision].
2].
The absence of any dedicated telephone lines situated in Brown County for communications between Brown County, Ohio, and Clermont County, Ohio, Campbell County, Pendleton and Bracken County, Kentucky EOCs, Ohio and Kentucky state EOCs, and the applicants' EOF.
[No plan provision].
i 3].
- ,y and all telephone contact with Brown County, Ohio, from and to Clermont County, Ohio, Campbell, Pendleton and Bracken Counties, Kentucky, EOCs, Ohio and Kentucky EOCs and applicants' EOF, would require use of limited long distance 5
~
-trunk lines involving the General and Bell telephone systems.
1
[No plan provision].
4].
Radio communications between base and mobile
~
radios utilized by Clermont County emergency response-support groups within an approximate area of four miles of the Zimmer Station in the near environs of U.S.
52 paraleling the Ohio River are incapable of radio transmission due to topographical 7
and land characteristics of that area creating blank, or void, radio transmission whereby radio signals meet natural. terrain barriers.
[No plan provision).
5].
The Clermont County Emergency Plan provides for communications among some of its emergency resource agencies by non-dedicated telephone line only, involving limited trunk service to certain agencies (one to four telephone lines),
utilization of long distance telephone lines involving Genera ~
Bell telephone systems, and as such this portion of the 1
communications plan does not provide a reasonable assurance that communications necessary to a timely and prompt evacuation can be implemented, especially where l'imited trunk lines 'f6r
~
telephone usage are subject to overload, e.g.,
I i].
Communications between 'the Superintendent of the Clermont County Board of Education-County Eoc and the Superintendent of the Felicity-Franklin School District requires use of limited long distance trunk lines, subject to overload, between Bell and General telephone systems:
Felicity-Franklin Superintendent has three trunk lines for use in 6
.l communications between the County Superintendent and to. summon s.chool bus drivers (approximately 18) to the schoo1~ site for-student evacuation; ii].
The Superintendent of Bethel-Tate School District has two telephone trunk lines, subject to overload, for use in communications between the County Superintendent and to summon school bus drivers (approximately 15) to the i
school site for student evacuation; iii].
The Superintendent of the New Richmond
-~
Schaul-District has four telephone trunk lines, subject to overload, for use_in communications between the County Super-intendent and to summon school bus drivers (approximately 17)
I-to the schon site for student evacuation and for telephone c)mmunicationa to the Monroe and Pierce Elementary Schools i
within the District, each school has two telephone trunk lines; iv].
The telephone trunk lines for each of.the affected school districts will be overloaded during emergency situations due to parental telephoning into the schools; v].
All noti cications to the County Superintendent, affected school districts, reception school districts, school district transportation supervisors, and school district bus drivers is ry non-dedicated, existing telephone trunk lines.
[ Plan, SII-E, Table E-1, pp. II-E-3 and 5; SIII-A, p.
III-A-2; 1
SIII-C, pp. I * "-C-1 through 3 ].
d 7
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, m r as necessary, ifails to provide reasonable assurance that monitoring'of persons and i-decontamination procedures will be implemented. [ Campbell Plan, Annex F,fProtective Actions,. p. F-9-1].
10].
The procedures in Clermont and. Campbell-Counties to' acquire lists of disabled, handicapped and senior citizens requiring special transportation fails to provide reasonable assurance 1by the plan or in its implementation that all such individuals are identified and that adequate vehicles and personnel'are available and dependable to enter the plume exposed area to evacuate such individuals. [Clermont Plan,'SII-B, Emergency Response Support, p.
II-B-1; SII-I, Protective _ Response, l
p.
II-I-5; Campbell Plan, Annex F, Protective Actions, p. F-9-1].
i 25.
The monitoring devices selected - and their placement offsite for the monitoring of releases, anticipated and accidental, of radioactive materials, _ including plume exposura in the event of accident, as to the location are inadequate to protect the health and safety of the polulation of Clermont County, Ohio, and as the same applies to the monitoring of releases into the Ohio River,and other sources of water for human consumption, as the same affects drinking water, plant and animal life of that 51 e
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t waterway tnd area within the plume exposure which are subsequently consumed by the population of the county;. and the inability of such monitoring to adequately and timely inform the applicant and local and state agencies and.related dissemination of uuch information to and for the protection of the piblic's health and safety.
Specifically.
~
1].
The agreement between the applicant and the City of Cincinnati to provide monitoring equipment and related information to the City of Cincinnati provides no reasonable assurance from the said agreement or the county and state emergency response plans that such information obtained by the applicant or the City of Cincinnati will be disclosed, or promptly disclosed to the responsible personnel of Clermont County, Ohio, and there is no reasonabale assurance that the responsible personnel of Clermont County would undertake prompt and protective action upon such advice. (No plan provision].
2].
The Clermont County Health Department has failed
. ' establish a radiation health unit and will continue into the future to fail to establish such u. t.
The local health depart-ment has no plan to collect and will not-in the future collect any baseline health data on neonatal hypothyroidism, infant mortality and cancer incidence for Clermont County and the department has no desire or capability to commence to collect such data, to establish the mile-radius of the Zimmer Station as a boundary for such data collection or the establishment of baseline data for water, milk, fish, vegitation form and aquatic 52 e
+
c-
9 organisms.
The department has failed to provide any imput into the preparation of the Clermont County emergency response plan as the same relates to departmental responsibility and cooper-ation with other county agencies, especially in the monitoring of liquids and solids ultimately consumed by humans.
The depart-ment has failed to institute any plans, and will continue to do so in the future, for the creation of training programs for local" physicians and other health care personnel in the management of radiation injuries or the monitoring thereof.
The department has failed and will continue to fai.' into the future to gather data pertaining to Zimmer employees, after the station is operational, to determine radiation exposure from both occupational and non-occupational (medical and dental) as a continuing monitoring program. The department has failed and will continue to fail to be prepared to institute a population registry, in the event of nuclear accident, for monitoring of the health effects to the population within the 10-mile radius of the Zimmer Station and to compare monitoring information with previously prepared baseline data.
The department has failed and will continue to fail to develope a plan for placement of enviromental monitors within the 10-mile plume exposure pathway and within the 50-mile ingestion pathway zone for monitori ;g the radiation to water, milk, veg-itation form and livestock subsequently consummed by humans, or for sample collection and analysis during normal operation of the Zimmer Statation and after an unscheduled radiation release.
The department has failed and will continue to fail to collect data in its monitoring of milk, fish and agricultural products intended for human consumption. The combined and individual failures 53
to institute, or into the future institute, monitoring programs for the health and safety of the affected population fails to provide or implement reasonable assurances that monitoring will be conducted and appropriately analyzed to protect.the health and safety of the population. [No plan provision].
3].
The Clermont County Board of Health and the Clermont County Cooperative Extension Service are jointly responsibile for the monitoring and evaluation of the impact of radiation release upon county farm products and livestock and based upon such monitoring and assessment will institute protective actions pertaining to milk and livestock feed control.
The plan provides no procedure and no procedure can be implement with reasenable assurance for the protection of the public that live-stock and dairy cattle within the monitoring range can be provided stored, closed feed, removed from pasturing, that facilities exist at the respective farm to remove livestock from field and house them and to store in sufficient quanity feed in closed containers, and to monitor that such protective agricultural j
practices are followed at the farm level. [Clermont Plan, SIII-A, County Agencies (Gen), pp. III-A-3 and 10; otherwise no plan pro-vision].
l 4].
There is no provision for the monitoring of milk produced in the EZPs and transported in bull. to a processing and bottling facility for distribution to retail groceries and subsequent human consumption. [No plan provision].
26.
The monitoring equipment, onsite and offsite, is in inadequate for the independent monitoring by local agencies, 54
conjunction with applicant's monitoring, for the purpose of pro-4 tecting the public's health and safety in radiation release, radio-active effluents anu plume exposure in the emergency situation and the interest of the pubiac in such irformation.
Specifically.
1].
The City of Cincinnati, as reflected by its agreement with applicant, is provided with monitoring equipment and delayed information pertaining current monitoring readings.
Clermont County has no such equipment or the ability to be informed of current radiation releases from the Zimmer Station, whether airborne or discharged into the Ohio River.
To provide l
reasonable assurances for the protection of the population's health and safety it is necessary that Clermont County be provided monitoring equipment and sending devices to exercise a failsafe judgment on Zimmer personnel given access to such monitoring devices so that local personnel are simultaneously provided the information presented to Zimmer personnel and can make independent judgment as to the potential threat to the public's health and safety and to promptly institute protective action to safeguard 1
the interest of the public.
The absence of simultaneous and identical information to provide independent exercise of judg-ment by local and Zimmer personnel creates a credibility problem borne of recent dissemination of incorrect information to the public and local and state agencies, failure to take prompt pro-tective actions and ultimate detriment to the health and safety of the public (e.g.,
lessons learned at Three-Mile Island, and still being learned), which removes reasonable assurances that 55
the best interect of the public will be observed, including the health, se
. protection of that public. [No plan provision).
27.
L 5ence of appropriate type and placement of monitor-ing devices..,
i schools located within the 10-mile radius of the Zimmer Station, the absence of trained local and school personnel to observe such devices and to alert and advise school personnel to take appropriate protective action, as necessary, in which auch devices must timely advise of dosage exposure sufficient under applicable standards to require protective action to safeguard the health and safety of children so exposed to excessive dosage in the respective schools.
Specifically.
1].
School-age children are particularly susceptible to untoward health effects from radiation exposure.
A.J.
Jolley Elementary School is approximately 2 miles from the Zimmer Station, j
St. Peter &' Paul Elementary School is approximately 4 miles from the Zimmer Station, Monroe Elementary School is approximately five miles from the Zimmer Station, Grant's Lick Elementrary School and New Richmond Elementary, Middle and High Schools are approximate-ly six miles from the Zimmer Station, and the remaining schools are within the plume exposure pathway of the Zimmer Station. Monitors inspected monthly and delayed analysis does not provide any reasonable assurance that protective action can be taken to remove school children from the radiation effects previously received.
It is necessary for the protection of the health and safety of this susceptible group of the plume exposure population that monitors be. installed at each school with trained personnel given 56
the opportunity for daily inspection of monitors indicating current dose levels so that where dose level exceed tolerable levels immediate protective action can be sponsored to adequately protect the school child. [No plan provision).
28.
The absence of trained local and state personnel to conduct surveillance of monitoring devices installed in local agencies as pontended in revised contention 26 to alert and advise the public by independent judgment of excessive dosage amounts -
under applicable standards of radiation releases, radioactive effluents and plume exposure in the emergency situation; such 1
1 equipment to be installed in the affected counties EOCs; the necessity for 24-hour surveillance of onsite information equipment as contended in revised contention 26 to exercise independent judgment in determining the presence of an unusual event, alert, site emergency or general emergency developing or in being at the site, for simulataneous and protective action necessitated by such information as independently assessed by local personnel and the institution of prompt and timely protective action to minimize and reduce the exposure by the public to reasonable assure the public's health and safety.
Specifically.
1].
The reasons presented and identified in revised contention 26 are incorporated herein.
Upon obtainment of the requisite equipment it is necessary that a continuious staff be present at each affected EOCs for continuous monitoring of the Zimmer Station's activities, exercising independent judgment and initiating protective action as warranted by such information for 57 i
the public's benefit and protection.
This revised contention further provides for the opportunity of staf f at the local EOC to independently judge the severity of the erent in progress and not to rely upon the judgment factor and potential bias of appli-cant in hesitating to order evacuation and to permit the local staff to institute prompt protective action for the public's health and safety. [No plan provision].
. 2 9.
This contention is withdrawn.
30.
The absence of applicant's furnishing, or alternatively, inadequate furnishing, to the plume exposure pathway EPZ pop-ulation equipment and gear, including clothing, for use during an emergency and ensuing evacuation for that population's pro-tection against radiological exposure, including whole body and inhalation, and such failure, or inadequacy, as the case may be, 1
subjects the public to health and safety dangers and potential injury.
Specifically.
1].
Exposure to radiation is a known hazard.
The potentially for such exposure occasioned by severe accident is no longer open to debate.
The topography and land characteristics of the plume exposure area in both Ohio,and Kentucky constitutes i
a maze of roadways chacteristic to rural areas impeding safe and l,
prompt evacuation presenting traffic congestion and potential l
vehicular. mishap.
The area is subject to road impassibility in part or in whole for short and long durations due to flooding,
- snow, ice, and fog conditions during which an evacuation could be mandated but prompt evacuation impossible because of roadway i
conditions, coupled with limited resourses for snow and ice removal l
58
and police personnel to control traffic.
Issuance of protective garments and masks identical to that issued.to emergency worker's for their protection, including issuing dosimeters to the population with provision for periodic charging, would provide the reasonable assurance that the public would be protected during emergency situations requiring evacuation and exposure to radiation to minimze or remove untoward health effects to that population. The population has never been given the option of whether it desired to accept the risks apparent from the presence of a commercial nuclear power facility within its community and that community is entitled to each and every safeguard available to assure its protection against injury and to provide for its health and safety. [No plan provision).
31.
Clermont and Brown Counties, Ohio, and Bracken, Pendleton and Cnmpbell Counties, Kentucky, do not possess the requisite funds or the financial means for the purchase, installation and t
maintenance of the required equipment, the requisite personnel, the required training of its personnel or the creation of the necessary EOCs to provide adequate protection for the health and safety of the public and the applicant must be responsible for the expense necessary to achieve a state of emergency preparedness.
Specifically.
i l
1]. The applican' is required to provide local and state plans which provide reasonable assurance that appropriate protective action can and will be instituted and implemented to safeguard the healt:1 and safety of the public.
The involved counties, their respective political subdivisions, including 59
l school districts, do not have the requisite funds to provide the equipment and personnel necessary to present reasonable assurance that emergency resourse plans can be effectively implemented for the protection of the public. Clermont County will be entitled in the future to the collection of taxes from the operation of the Zimmer Station.
No other county will receive any tax benefit from that operation.
Clermont County would receive the same tax benefit from a coal burning plant as from a nuclear powered reactor, without the necessity for its involvement in the creation of emergency plans and the training of its several agenies and the obtainment of items of equipment to implement that plan. The responsibility to provide a plan which reasonably assures the protection of the public and which is capable of implementation is that of the applicant. In order to provide the necessaries to implement the plan to the full capability of providing a reasonable assurance that the public is adequately protected, the applicant must provide that equipment which the county, its agencies and the school district cannot.
Where school evacuation cannot be implemented in a timely and i
safe manner for the protection of the affected school children l
because of an inadequate number of school buses, drivers, radios, l
dedicated telephone trunk lines, an,d the school district can not provide the necessities because of lack of funds, the responsibility shifts to the applicant to provide the equipment where that equip-ment is necessary to implement the workabliity of the plan. The foregoing illustration is equally applicable to each agency involved in the implementation of the emergency plan.
The absence of 60 y
y
'?
-d
an item of equipment for which the plan cannot be implemented renders the plan inadequate.
(No plan provision].
32.
The adequacy of onsite and offsite organizations for coping with emergency and the adequacy of emergency preparedness must be evaluated in a test conducted prior to commencement of the operation of the Zimmer Station as a joint exercise-drill involving applicant's emergency resourse personnel and partial public participation, including partial school participation, within the plume exposure pathway of the EPZ, demographical, topographical, accessible site and evacuation routes and local jurisdictional boundaries being considered and examined, to determine the adequacy of implementing procedures and methods, the testing of emergency equipment and communication networks and timing, from which and due to the land characteristics, personnel, equipment and other relevant factors the state of emergency preparedness will not meet the required standards for the protection of health and safety of the populace within the EPZ in an emergency circumstances.
1].
The proof of the best of designed battle plans is the battle itself.
Short of the battle, maneuvers may provide some indication of the worth of the plan.
Evacuation time estimates, deploying of emergency resourse personnel, ability to cope correctly and promptly with a given situation, and the use of communication systems provides limited insight to the capability of the plan to correctly function. The critical aspects of the respective local plans is the discipline of the public to follow the direction of the protective action announced; the most demanding being evacuation, the conduct of that public in evacuation, the 61 w___
7-
actual time for evacuation -- not the estimated time -- of that population, the ability.of the school to respond, summons its buses and the times required, as actual times, to board buses and the buses to evacuate the student out of the plume area, the deployment of police and the abiJity of that unit to control traffic.
A limited portion of the population in ' the sector most difficult to evacuate in each county should be selected (accepting volunteers i f necessary), each school should activate its evacuation,at the most difficult time to commence an evacuation, with. removing the students from the school and boarding the bus, stopping the timing and discharging the students from the bus, and then permitting the empty bus to travel its evacuation route to conclusion of the evacuation of all students by mock boarding and actual transportation of the buses, provide directions to the public and schools, permit the police units to man the access control sites, summons of f-duty police of ficers, and observe by stop watch the times required for actual evacuation.
If injury and mishap is a consideration prompting denial of such a drill, consider the consequences of an actual evacuation which fails to accomodate the time, direction and educational exti ma tes. Unless a drill-exercise is per. formed to determine the ability to implement evacuation and determine the problems of land characteristics, ability of the public to respond, the abili y of the schools to respond, and the ability of the emergency resourse personnel to respond, there is no reasonable assurance that the plan as draf ted is in reality capable of being 62 s3
implemented.
[No plan provision].
/'
1 Dated: November 12,-1981 ANDREW B.
DfNNINON 200 Main Street Batavia, Ohio 45103 (513)'732-6800 Attorney for Intervenor ZAC-ZACK k
- 63 L.
UNITED STATES OF AMERICA NUCLEAR REGUI ATORY COMMISSION 00tKETED 1
ATOMIC SAFETY AND LICENSING BOARD
'JSHRC John H.
Frye, III, Chairman M.
Stanley Livington, Member
'81 NOV 16 P3:22 Frank F.
Hooper, Member gfj)
,'Q[(h6ECRE In.the Matter of g 5ER I BRANCH CINCINNATI GAS AND ELECTRIC COMPANY, ET AL.
DOCKET NO. 50-358 (William H.
Zimmer Nuclear APPLICATION FOR Power Station)
OPERATING LICENSE CERTIFICATE OF SERVICE I hereby certify that a copy of Revised Contentions for Intervenor ZAC-ZACK, dated November 12, 1981, were posted in.the U.S.
- Mails, postage prepaid for service upon the below named persons or agenies listed below, except those indicated by
- which were delivered to the office of C G & E Co. for separate transmittal.
e,
- John H.
Frye, III, Esq.
- Charles A.
Barth, Esq.
Chairman, Atomic Safety U.S.
Nuclear Regulatory Commiscio and Licensing Board Room MNBB 9604 U.S.
Nuclear Regulatory 7735 Old Georgetown Road Conmission Bethesda, Maryland 20014 Washington, D.C.
20555 Dr. Frank F.
Hooper, Member
- Troy N.
Conner, Esq.
Atomic Safety and Licensing Conner, Moore & Corbet Board 1747 Pennsylvania Avenue, N.W.
School of Natural Resources Washington, D.C.
20006 University of Michigan Ann Arbor Michigan 48109 t
Dr. M.
Stanley Livingston Atomic Safety and Licensing Appea Member, Atomic Safety and Board Licensing Board U.S. Nuclear Regulatory Commissio:
1005 Calle Largo Washington, D.C.
20555 Sante Fe, New Mexico Docketing and Service Section Atomic Safety and Licensing Board Panel Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissio:
Washington, D.C.
20555 Washington, D.C.
20555
- Will iam J.
Morgan, Esq.
l Mary Reder General Counsel Box 270 Cincinati Gas & Electric Co.
l Route 2 California, Kentucky 41007 P.O.
Box 960 Cincinnati, Ohio 45201 t
e r
John D.
Woliver, Esq.
James 11. Feldman, Jr.,
Esq.
P.O.
Box 47 Fifth Level 550 Kilgore Street 216 East Ninth Street Batavia, Ohio 45103 Cincinnati, Ohio 45202 George E.
Pattison, Esq.
David K. Martin, Esq.
462 E.
Main Street Assitant Attorney General Batavia, Ohio 45103 Acting Director Division of Enviromental L'.w Of fice of the Attorney Ger.eral 209 St. Clair Street Frankfort, Ke ucky 40601
.~,)
ANDREW B.'
ENNISON 200 Main treet
- Batavia, hio 45103 (513) 732-6800 e.
Attorney for Intervenor ZAC-ZACK 2
- _-- _ _ _