ML20033B980
| ML20033B980 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 11/25/1981 |
| From: | Woliver J CLERMONT COUNTY LEGAL AID SOCIETY, FRANKHAUSER, D.D. |
| To: | CINCINNATI GAS & ELECTRIC CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8112020542 | |
| Download: ML20033B980 (9) | |
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00f.KETED U9EC 81 NOV 30 P6:20 UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION
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..n In the Matter of Docket No.
50-358-OL THE CINCINNATI GAS & ELECTRIC DR. FANKHAUSER'S
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Pursuant t o the Board's November 5,1981, Pre-hearing Confe og d iscovery, Dr. Fankhauser hereby submits the following interrogatories to the Applicants under 10 C.F.R. 52.740(b).
All information relating to these interrogatories in the possession of the Applicant s, it s of ficers, agents, employees, at t orneys, and consult ant s, part icularly the Stone & Webster En-gineering Corporation, should be provided in Applicants' answers. The Appli-cants are under a cont inuing duty to supplement or amend their answers as necessary and as circumstances dictate.
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8112O20542 011125 DR ADOCK 05000358 PDR
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1.
Describe in functional terms all the monitoring equipment to be in-stalled in or around the Zimmer Power St'ation (hereinafter Zimmer) which will record for both the Applicants and state and local governments or agencies any gaseous radioa'et ive emi-ssions or releases from Zimmer; and, wit h respect to each monitoring apparatus, include the following:
a.
The types of radioactive isotopes to be monitored; b.
The monitoring range of each apparatus; The location (s) and person (s) who will receive the c.
monitoring informat ion; d.
Whether it will be in cont inuous operat ion or will be t riggered into operation upon the occurence of an event such as a radioactive release above a speci fied quant ity.
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n 2.
With respect to the proceeding answers, stat e whether there will be and describe in funct ional terms devices to be used in conjunct ion with the monitor-ing equipment at or around Zimmer which would be able to chart the probable direction, velocity, disperssi rat e and magnitude of rad ioact ive releases into the atmosphere.
Describe how this information will be used and what persons will have direct access to it.
~a 3.
With respect to the Clermont County Radiological Emergency Response Plan (hereinaf ter CCRERP), state what studies have been made t o calculate the number and locat ions of " mobility impaired" persons in Clermont County.
If no such studies have been made, s t at e:
(a) whether such studies are planned; and (b) who will perform such stud,ies; and (c) describe how such studies will be made.
4.
With respect to the CCRERP, st ate what assumptions have been made about the foi lowi.ng:
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The amounts of t ime it will take local officials or others to render evacuat ion routes -in Clermont County passable subsequent to a:
(i) three inch snowfal1;
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(ii) six inch snowfall; (iii) twelve inch snowfall.
b.
The additional amounts of time it will take to evacuate the populace in Clermont County if there is a:
4 (i) three inch snowfall; i
2 (ii) six inch snowfall; (iii) twelve inch snowfall.
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5.
Describe all studies that have been used to calculate the in format ion provided in the proceeding answer.
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6.
In the CCRERP, several organizations and agencies, which are comprised in whole or in part by volunteer members, are given responsibility to implement aspects of the emergency plan.
For each such agency or organizat ion, ident i fy the number of persons by position who have some responsibility in implementat ion of the emergency plan.
7.
With respect to the an'swers to the proceeding interrogatory, state whether.any survey has been performed to ascertain the accessability and pro-bable locations of such volunteers during both working days and other times.
If such a survey has been conducted, attach a copy to your answers.
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8.
Describe all t raining by posit ion for each member of the Clermont Count y Sherif f's Of fice and the Clennont County Disaster Service Agency which
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has been or will be provided so that all persons wit h these agencies will be fully t rained t o fullfill their funct ions described in the CCRERP.
9.
State whether or not surveys have been completed to ascert ain the number of employees of the Clermont County Hospital who resid: within a ten mile rad ius of Zimmer.
If such a survey has been conduct ed, please at tach a copy to your answers.
10.
State whether any surveys have been completed to ascertain the numbers and locat ions of both livestock and domest ic animals who res ide within:
(a) a ten mile radius of Zimmer; and (b) a fifty mile radius of Zimmer.
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surveys have not been completed, state whether such s6rveys are-planned and describe how these surveys will imp l eme nt ed.
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With respect to implementation of the CCRERP, state what assumptions, considerat ions or planning have been made about t h ey, t en t, i f any, of public r/*
disobedience or indifference to evacuation or~ ether instruct ions.
If any'such assumpt ions, considerat ions, or planning c'oncerning public disobedience or t
indifference to evacuat ions or other inst ruct ions has been made, state what th'e possible ef fects of such public disobedience or indifference would have on 'the z
overall effectiveness of the CCRERP.
12.
Identify by interrogatory number-the names, addresses, and place of employment and posit ion they are in, all personsAho answered or cont ributed to
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each answer, cxcluding clerical personnel; and[for each such person, set forth a
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st atement~ of the professional qualificat ions.
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7 Answers to the foregoing should be submitted in writ ing and under oath and
,f served upon the undersigned counsel for Dr.- Fankhauser with'in 14 days of service ff therof.
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Respect ful ly Submit t ed,
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'~ ohn Woliver Attorney for Intervenor Dr. Fankhauser
,y, j-Cle rmont County Legal Aid Society P.O. Box #47, 550 Kilgore St reet Bat avia, Oh io 45103 (513) 732-2422-i' CERTIFICATE OF SERVICE m
I hereby_ certify that true copies of the foregoing were mailed to the following this.2 i' day of 3 W e of. h 1981.
John H. Frye III Michael C. Farrar, Esq.
Chairman, At omic Safety At omic Sa fety and Licensing k
d, and Licensing Board Appeal Board t'/,'
U.S. Nuclear Regulatory U.S. Nuc lear Regul at ory Commission Commission y
Wa sh i ngt on, D.C. 20555 Washington, D.C. 20555
.A Dr. F:ank F. Hooper, Member Chairman, At omic Sa fet y and Atomic Safet y and Licensing Licensing Appeal Board Panel Board U.S. Nuclear Regulatory School of Natural Resources Commission Univers it y of Michigan ko sh ingt on, D.C.
20555 Ann Arbor, Mich igan - 48109-Dr. M. St anley Livingston ?
'Oiairman, At omic Sa fety and
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At omic Sa fet y and Licensing, U.S. Nuc lear Regulat ory Licensing Board Panel Board 1005 Calle Largo Commission r
S a nt a Fe., New Mexico 87501
Wash ingt on, D.C.
20555 1
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Charles A. Bart h, Esq.
Richard S. Salzman, Esq.
Counsel for the NRC St af f Chairman, At omic Safety and Office of the Execut ive Legal Licensing Appeal Board Direct or U.S. Nuc lear Regu l at ory U.S. Nuclear Regulatory Commission Commission Wa sh ingt on, D.C.
20555 Washingt on, D.C.
20555 Mr. Chase R. St ephens James Feldman, Esq.
Docket ing and Service Branch Attorney at Law Of fice of t he Secret ary 216 East Ninth St reet U.S. Nuclear Regulatory Cincinnati, Ohio 45202 Commission Wa sh ingt on, D.C.
20555 William Moran David K. Mart in, Esq.
Cincini.at i Gas & Elect ric Company Assistant Attorney General P.O. Box 960 Act ing Direct or Cincinnati, Ohio 45201 Divis ion of Environment a l Law Office of At t orney General 209 St. Clair St reet Frankfort, Kent ucky 40601 Mrs. Mary Reder George Patt ison Box 270 Prosecut ing At torney of Rout e 2 Clermont Count y, Oh io Cali fornia, Kentucky 41007 Main St reet Bat avia, Oh io 45103 Andrew B, Dennison, Esq.
Attorney at Law 200 Main St reet Batavia, Ohio 45103 Troy B. Conner, Esq.
Conner, Moore and Corber 174 7 Pennsylvania Ave., N.W.
Wa shingt on, D.C.
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John Woliver s