ML20033D049

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Response to Applicant First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl
ML20033D049
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 11/30/1981
From: Ryan Alexander
OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8112070157
Download: ML20033D049 (13)
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Text

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ovember 30, 1901 UNITED STATES OF AMERICA NUCLEAR REGULATORY COICISSION

'81 DEC -3 P4:57 p Before the Atomic Safety and Licensing Board In the Matter of ) ) CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 fl' COMPANY, Et A1. ) 50-441 t- ) (Operating Licens fh'Y. (Perry Nuclear Power Plant, ) Units 1 and 2) ) 'J, ) S, DEC4 d 1901 ~

  • 1 OCRE R GPO!!SE TO "APPLICA!!TS' I:: ten'OGATORIES col $e@*

9 A!!D PIQUEST FOR P20DUCTIO:! OF DOCII'E::TS TO II"f2RVEM0? O!!IO CITIZE!!S FOR n:SPOI'3ISLC E 'EnGY (FIP.ST S2"' @* / /k \\ >p \\ (To concorve its cearec recources by cuttins duplication and posta;c cocts, Ohio Citicenc for Responsible Cncray ("OQ22") will not reproduce here the interrogatorico propounded it. CC?I will recpond to those interrocatoriec ucinc the came ccquenco and numeration encountered.) ISSUE "0. 1 (Anglicants' Cacreency Evacuation Plans 1. Dr. Jan Scyca, Senior Energy Scientist for the Untional Audobon Society. (Dr: Scyca ached to be contacted e::clucively throunh CCRC channelc.) 2. Dr. Jance Scott,13935 Ivynount, Sugarland, TX 77470. Dr. Scott is self-employed. Iiis titlec are: Phycicict, Chonist and Lav/cr. !!ic educational and profcccional qualificationc are as follous: B.S. Chemistry, Phycies, and !"athematicc,10G4; he graduated with hinhect honorn; !!. S. Phycies, Univercity of To::ac,10GG J.D. Univorcity of Houston,1977 Lmr/ crc in enca, nenber (b), (c), and (d) Broadly put,::r. Scott will testify.on physical phononena the c::act nature _of which chall be clarificd later b,- thic Intervonor. 3. "?rotection of the Thyroid Gland in the : vent of Rolcaccc of nadioicdinc," MCRP Report Co. 55, Reconnendation of the Mational Council on Padiation Protection and I:cacurements, Au;uct,1077. " Criteria for Preparation and Evaluation of Radiolo';ical Encrnency neaponce Planc and Preparednoca in Support of nuclear Power Plantc," 13ln2G-0054, FC:2-?;P-1, novicion l, novceber 1030. p3 ' ~ J It '8112070157 811130 PDR ADOCK 05000440 C PDR j

I s-10 CFR Part 50, section 50.47 and App. E. FSAR for P!TPP, App. 13A. " Functional Critoria for Emernoncy Response Facilitics", !!UREG-CC90, February 1981 "Threc ?!ile Island: A Report to the Commiccionere and to the Public," fiUREG/CR-1250 (Rogovin Report), Vol. II, Part 3, pp. 993-1051. Examination of the Use of Potassium Iodido (KI) as an Emergency Protective IIeasure for Nuclear Reactor Accidents," IIUREG/CR-1433, David C. Aldrich and Roger !!. Elond, March 1980 " Radiation Protection: An Analysis of Thyroid Blocking," by David C. Aldrich and Roger I!. Blond. A paper presented at the International Conference on Current I!uclear Power Plant Safety Issues, Stockholm, October 20-24, 1980, IAEA-Cri-39/102. " Emergency Planning for Reactor Accidents," by Dr. Jan Boyca, The Bulletin of Atomic Scientists, December 1980, pp. 40-45. " Testimony of FE!!A's Vernon E. Adler and Frederich J. Bath on Contentions Related to Offsite Emergency Planning," T!!I Rectart proceedings, Docket No. 50-289, March 16, 1931. " Testimony of Frederich J. Bath and Vernon E. Adler of the Federal Emergency Management Agency on Certain Offcito Emergency Planning Contention.m " T 1I-1 Restart proceedings, Dochet I!o. 50-289, February 23, 1981. " Stockpiling of Potassium Iodide for the General Public as a Condition for Rectart of' TMI Unit 1", Direct Testimony of Dr. Jan Boyen on behalf of the Anti-Nuclear Group Reprocenting York regarding ANGRY Contention !!o. III B(D), TIII Restart proceeding, Dochet ::o. 50-209. " Emergency Preparedness Evaluation for TI:I-1," IIUREG-074G, December 1980, and Supplement 1, May 29, 1901. "Licensco's Testimony of Robert E. Rogan, George J. Giangi, and Alexis Tcaggario on the Adequacy of Onsite Emergency Preparedness at Threc Idle Island, Unit 1," TI:I Rectart Proceedings, Dochet I o. 50-233, February 9, 1901. "Tectimony on Behalf of the Anti-1:uclear Group Reprocenting York On IIunicipal and School Energoney Planning in York Co., Pa. and York County Emergency Response to Threc !!ile Island," by the Leasue cf Uomen Voters of Greater York (Pa), !! cry Ryccavano, !!d., Arleno.::iner, a..d Judith !!illiard, T!!I Restart proceedings, Dochet tio. 50-289, April 27, 1981. 2-

fs "Tranceript of T:!I-1 Rostart Hearin~,c, Dochet No. 50-289, date pagen ? 13771-2 ! arch 5, 19S1 14239-40, 14377-8 March 10 14620-628 March 11 15045-4G !! arch 12 15136, 15140, 15152-3 April 4 17665-6 April 8 13161-2 April 9 10338-18795 ? 19069-19075 April 16 19342-3 April 17 19396-19403 April 21-19639-19645 April 30 20796-97, 20080-1 !!ay 1 20894-5, 20912, 209G7-8 May 15 21508, 21589, 21G21-2 " Suggested Policy of the Food and Drug Administration on the Use of Potassium Iodide by the General Public in a Radiation Emergency", by Gordon Thompson, PhD and Patrich Darton, II! tern, Union of Concerned Scientists, August 1981. 4G FR 30199, IIotice of Avillability of Draft Rocommendations on Uce of Potassium Iodide as a Thyroid Blocking AEent in a Radiation Emergency, Docket No. 81U-0087, June 5, 1981. " Background Material for the Development of the Food and Drug Administra-tion's Recommendati,ons on Thyroid-Bloching with Potascium Iodide," prepared by the Bureau of Radiological IIcalth and Dureau of Drugs, April 1981. " Guideline. Labeling for Potassium Iodide for use as a Thyroid-Blocking Agent in a Radiation Emergency, Dochet No. 78D-0304, FDA-(availability announced December 15,1978 (43 FR 50700). "Motico of Changes;to Labeling Guideline, 'Fotassium Iodide. as a Thyroid-Blarking Agent in a Radiation Emerger:cy, August 17,-1979, 44 FR 48347, Ds%e t No. 7CD-0343. - Statement by Joseph P. !!ile, Acsociate Commissioner for Regulatory Affairs. and Jamco S. Dencon, Deputy Director Bureau of Radiological Health. Food and Drug Administration Defore the Subcom=itto on Nuclear Regu-

lation Committec on Environment and Public Uorks, United States Sonate, April 27, 1981.

b 45 FR 11912, "I*otice of Approval and Availability", FDA-Docliet no. 00U-00G3. The FDA hac-approved two New Drug Applicationu for KI fron: Uallace Laboratories. 3 9 a 4

" Summary of " aces of Approval for UDA 18-303 and MDA 18-307, " Thyro-31ock Solution" and " Thyro-Block Tablets" from Vallace Laboratories. 1 41 FR 38012, September D, 107G, "Over-the-Counter Drur.c: Ectablichmen. of a !!onograph for OTC Cold, Couch, Allergy, Cronchodilator and Anti-asthmatic Products," also at 38357, the une of iodides as c:cpectorante. 43 FR 58700, December 15, 1978, " Accidental Radioactive Contamination of !!uman and Animal Fecdc and Potaccium Iodide as a Thyroid-Dlocking Agent in a Radiation "mergency," FDA. " Report to the President," FEMA, June 1080, pp. Ex-2, III-28 throur,h III-32 " State of Ohio Iluclear Power Plant Emcrconey Responce Plan," December 1980, prepared by the Adjutant General's Department Disaster Services Committee.' I " Staff Report to the President's Commission of the Accident at Three :Ille Island," Report of the Emergency Preparedness and Recponce Tach Force, October 1970. "Available Thyroid Protection," Science, Vol. 204, June 8,1979 at 1032, letter from Franh von Hippel. 4 OCRE has not identified which documents will be used in this manner. 5. (a) Potaccium iodido (KI) chould be distributed to every hourchold within 10 miles of the plant and stochpiled at tuo hospitals for the follou-ina reasons: (1) Radioactive icotopes.of iodine are produced in abundance by the ficcion procesc in nuc1 car reactors (IAEA-CH-39/102 at 2 and Science, Vol. 204 at 1032). (2) These isotopes, either in olomental form or in iodine compounds, aro quito volatile and therfore are available for atmospheric relcano in the event of a nuclear accident.- Ibid. (3) Radioiodino in readily abcorbed by the body after inhalation, and additional abcorption can occur through the,r;rass-cow-milh feod chain (Seyca, Oull. tin of Atomic Geientists at 41). (4) Iodinc in colectively abcorbed by the thyroid cland; the body cannot dictinguich tatucen stable and radicactive iodino; this concentration of radioiodine 'in.the thyroid cland can cauce local radiation damage, reculting f neffects 'cuch as hypothyroi-dicm and thyroid nodulco, about 00-45% of uhich are cancerous. FDA Draft Recommendationc, April'1981 at 7. 4

(5) The use of KI as a thyroid bloching acont can markedly decrease the uptake of radioiodino by the thyroid cland; however, to be effective, the KI nuct be insected juct prior to or simulta-neously with the exposure to radioiodine. The effectivenecc of KI after inhalation and/or ingcction of radioiodine decreases rapidly with time. ITUREG/CR-1433 at 10. (G) The FDA has approved two new drug applications (from 'elallace Laboratoriec, " Thyro-Bloch Solution" and Thyro-31och Tablets") for potaccium iodide as a thyroid bloching agent in a radiation energency. 45 FR 11912, February 22, 1980 and " Summary of Ences of Approval for UDA 18-303 and UDA 18-307. (7) The FDA.concludoc that under the conditions of use in a radiation imergency (130 mg KI, daily for those persons over one year of age, for up to ton days) potassium iodido is cafe and effective. 43 FR 58790 " Conclusions". (3) The National Council on Radiation Protection recommends the use of thyroid blocking agents when projected thyroid radiation doces excocd ton (10) rado. NCRP Report Mo. 55 at 32 (D) Predistribution of KI ic escential for its timely and offective use. See the foll Wing quote from the UCRP Mo. 55 at 2G-27: Since offectiveness against thyroid uptahe of radioiodince depends upon the almost instant availability of bloching agents, every available appropriate outlet chould be considered as a a stockpiling and distribution point. In dctormining cuch stationc, a consideration should be given to population concentrations in relation to the facility. Stockpiling and distribution conterc can include the nucicar facility, firchouses, polico stations, hospitals, clinics, factories, office buildings, municipal buildingo, schools, physicianc' and denticts' offices, pharmacies, and other facil-' ities where normal medical emergency services are usually availabic. Thic report docc not develop details of stochpiling and distribution cinec, if those methods are to be used, the implementation is best determined by local authoritics and the operators of the nuclear facility.- Since early stecca to blocking agents is of utnoct import-ance and the blocking agents arc ino::poncive, redundancy is desirable and wastage is not a prime consideration. Suppliec of potaccium iodido can be otored in a variety of placec, including _ homen, especially for those dictant from -the provi-ously listed distribution conters,.and those who anticipate difficulty in ' reaching :such centers becauf.c of lack of trans-portation, difficulty in ambulation, traffic congestion, or weather conditions." G -5 p ~~

(10) FC:"A has urged that potassium iodido be stochpiled for use in radiological emergencies. " Report to the Precident," FEMA, June 1900, at Ex-2 (11) According to Dr. Jan Beyea, the availability of potassium iodide may aid in an efficient and orderly evacuation by reducing panic among the evacuces, cince they would know that KI is available as a bachup mencure. Direct Testimony,.TMI-l Restart proccoding at G. (12) Thyroid bloching agents are uced around nuclear facilities in other countricc. Sweden is planning to issue KI to residents within,a 20-hm radius of their four nuc1 car power plantc. Seyea Tectimony, T"I-1 Restart proceeding at 9. In England, potassium iodate (KIO s used. UCRP Report No. 55 at 23. 3 (13) Just recently the Stato of Tennessee has decided to distributo KI to people living near the Sequoyah nuclear power plant. AP, Hovember 3, 1981. (14) The Applicant has made no provie'on in its FSAR for the use of radioprotective drugs by the general public or by emergency worhers, and neither has Alan M. Voorheen and Associates, an agent of Applicant, in the Evacuation Study, Appendix D of Appendix 13A of the FSAR. The only mention of thyroid blocking agents is in Section 6.5.2 of Appendix 13A, and this pertains only to CEI employecc. Thuc, the Applicant's emergency plans have not fulfilled the requirements of MUREG-0654, Planninr, Standard J, " Protective Response," Evaluation Criteria Gc,10e and 10f. Note that that docunent also recommends thyroid prophylanis an a protective meacure. Id. at I-51. (b) (Ecferences arc provided with the response to 5(a) above.) (c) (Sco OCRE response to Interrogatory number 1.) (d) Unknown at this time. Thic information will be provided at a later date. ISSUE MO. 2 (Financial necnoncibility) Reflecting the spirit of OCRE's telephonic contact on "ovecber 16,10S1 . uith Applicants' counsel, OCRS respectfully declince to answer Interrogatories C throu;h 13 pertaining to Applicants' financial' responsibility at this point. It was agreed then that mattern related to thic incue would be put on hold ~ pending the outcome of the current rulemaking on 10 CFR 50.33(f). Counsel for Applicant _ indicated that resolution of the matter was forthcoming ("around tho' end of the year") and if not, all related affairs, such ac these; interrogatories,- could be " resurrected."

0 o, 4 Issue No. 5 (Scram Diccharco Volu:.c)

14. Robert Alo::ander,. 2030 Portsmouth St. #2, Houston, "'X 77090.

Mr. Alor.ander ic employed by the Houcton Independent School Dictrict.

15. (a)-(d) Un:nown at this time. This information will be provided at a later dato.

1G. Memorandum for Harold h)enton from Carlyle !!ichel' son dated August 1,1900: "AEOD Report on the Browns Ferry Three Partial Failure to Scram on June 20,1980." lIinutes of the ACnS Fluid Dynamics Subcommittec Mocting, Los Angelos, CA, August 19-20, 1900. " Safety Concerns Associated with Pipe Breaks in the Bla Scram System," UUnEG-0705, May 1981. IE Bulletin No. 80-17: " Failure of 76 of 185 Control nods To Fully Insert During a Scram at a B12." IE Bulletin no. 80-17, Supp. No. 1. IE Bulletin No. 80-17,Supp. No. 2: " Failure Rovealed by Testing Subsequent to Failure of Control Rods to Insert During a Scram at a St'R." Memorandum for Dr. I!ilton S. Plescot from Members of ACES Tash Force dated August 8, 1900: "A Review of Recent Malfunctions of Et'n Scra= System." Article in Energy Ucers Report (April 9, 19S1) at 647 rc: SDV Pipe Breaks. IE Information Motice Ho'. 20-45: " Potential Failure of B*cm Bachup :*.anual Scram Capability," dated December 17, 1900. IE Information Notico no. 80-43: " Failure of the Continuous '!ater Level Monitor for he Scram Discharge Volume at Dresden Unit #2." Lotter to Donald P. Disc (Hincara Mohawh Power Corp,) from Thomas A. Ippolito,1:2C Division of Licensing, dated May 13, 1931. Amendment No. 43 to DPR-G3 and related safety evaluation by Staff. " 2C Eyes Problem In Reactor Plumbin?,," Uashington Post-(April 0, 1931) at AD.

17. OCRE has not identified which ' documents will be uced in this manner at this time.
10. (a) OCn: adoptc, with the note below, tho'."Diccuccion of Safety Concerns" in :,"JnEC-0705 (ccction: 2-1 throuch 2-S').

Thic Intervonor is currently 7 9

e. o unsure of design differences between the :'. ark III and the earlier

  • ark I and II models with respect to the 3DV system and its location within containment. The P:!?P PSAn does not verify the differences onc way or another. Pendin; further discovery on this issue. OCnt will retain for its factual bases of this contention the IIUK 0-0705 c::planation.

(b) 2eforences included in response to number 10(a) above. (c) (See response to Interrogatory 14.) (d) Unknown at this time.

19. (c) By " demonstrate the safety", OCEE intends that the Applicants should meet the applicable criteria found in Appendi:: A of 10 CFn Part SC.

Specifically general design criteria 54 and 55 which require that reactor coolant pressure boundary pipin?. systens penetratinF, primary containment be provided with rodundant isolation and containment capabilities which reflect the importance to safety of isointing these piping systems. !!UREG-0705 at 11. (b) References included in response to number 19(a) above. (c) (Sec response to Interrocatory 14.) (d) Unknown at this time. Issue :o. 7 (Clam 31ofoulini)

20. Jeff Alexander, 929 Uilmington Ave. fH, Dayton, OH 45420.

Mr. Jeff Alexander is a student at the University of Dayton. Robert Warneke, 3262 Branard #18, !!ouston, T:: 77008. !!r. Warnche is a student at the University of Houston. Robert IIcMann, Arlington, Te: as. Mr. Mc:! ann is a researcher at the University of Te::as.

21. (a)-(d) Unknown at this time. This information will be provided later.
22. ::otes of ::ecting with A!!O concerning clams by M. Masnik.

" Asiatic Clams Cause Shutdown of Arkansac -!!uclear One _ Unit 2," by M. !".asnik, 2nvironmental Engineering Branch,' U.S. !!.R.C.. Letter to Director, IRR, IRC, from W. Cavanauch, III, AP&L dated September 18, 1980. ~ 8 1 O +

o. P::0-IV-CO-2SA dated September 18, 1980. Itemo to R. A. Clarh, DOL, from R.L.Ballard, DE, dated *0eptember 19, 1900. L::R 00-065/031-0 dated October 10, 1980. !!emo to H.R. Denton, f:RR, and V. Stello, Jr., I&E, from C. ::ichelson, ACOD, dated October 21, 1900. Agonda/imC-AP&L Ileeting on AI:0-1 and AI!O-2 Service "ater System Fouling, dated October 22, 1900 I Letter to Director, I:2R, IRC, from D.C. Trimble, APOL, dated Decem5er 2, 1980. IIemo to T. !!.:: oval:, DOL, from D. R. : uller, DE, dated 2: arch 2,1981. Letter to Director, I!.R.R., !!RC, from D.C. Tricole, AP&L, dated !". arch ':0, 1981.

emo to V. Otello, I&E, from C. :ichelson, A20D, dated :* arch 31, 1901.

PI:0-II-01-31, dated April 27, 1981. Letter to P. J. O'Reilly, ::RC, from R.~ C. Diet =, CP&L, dated April 30, 1301. PI:0-II-81-33, dated ::ay G,1981. Lotter to 3. H. Grier, ReEion I, I:RC, ' from I. R. Finfroc:,, Jr., JCP&L,- dated Ifay 14,1981 - LER 31-017/03L-0. Letter to J.P 0'Reilly, !!RC, from C.R. Diets, dated !!ay 19, 1931. O F 6 0 0 A

0 Letter to north Carolina Ucpartment of !Iatural Resources and Community Development from t'. A. Haller, Duke Power Company, dated June 4,1901. PMO-V-81-33, dated June 9,1931. Notes of Meeting at Brunswick on June 17, 1981, by M. "asnik. Attendance List - AEOD-SSEP Visit, June 17, 1981. Letter to Region V, NRC, from J. G. Haynes, SCEC, received July 8, 1981. !!cmo for the file from Eugene Imbro and Joan Giannello rc: Loss of Residual Hocr Removal Capability at Brunswic!: Units 1 and 2, dated July 22, 1981. UUREG/CR-1350: " Evaluation of Factors Effecting Toxicity of Clorinc." Brunswich Steam Electric Plant Unit Hos. 1 and 2: Rosponse to IE Bulletin S1-03, dated May 2G, 1931. LER dated !!AY19,1901 for event which occurred May G, 1981 regarding shell blockage in RHR heat exchangers. IE Information Notico No. S1-21, dated July 21, 1981. " Interactions of Corbicula sp. with Power Plants," by J.S. !!attice, Environ-mental Sciences Division, ORUL, presented October 13-15,1977. " Control Studies on Corbicula For Steam-Electric Generating Plants," by L. B. Goss et al., presented October 13-15, 1977. 23. OCRE has not identified which documents will be used in this manner at this time. 24. OCRE objects to this interrogatory in its entirety.and respectfully declines to answer same. The issue is moot: "Corbicula'has been found in Lake Erie...." Detroit Edison Response to IE Bulletin 31-03, dated April 10, 1981 at 1. A response to -this interrogatory would be pointless. 25. B.A. Botany, Zoology; !!1ami University,1979 II.S. Biology; University of Dayton, (April, 1982) Thesis: " Population Energetics of the Freshwater Clan Musculium Lacustre." (b) "r. Jeff Ale::ander has conducted periodic sampling of corbicula -population in Dayton, Ohio. 2G. - '(a) Yes. (b) OCRE response is premised on corbicula's introduction into the Plant's auxiliary cooling systems-through the' e:: traction of la!:e water bearing corbicula larvae. The larvae will settle out in a slow moving column '10- ~ w

.o 4 of uator and attach themselves. Given cubacquent reproductive cycles, the incroaco in both the population cice and the cice of the organism vill degrade flow ratcc in the cooling system, particularly in condensors and heat exchanners. A latency period of cightcon nonths to three years after initial plant operation will pacs prior to significant fouling problems. This is due two factors: First, the enctward migration of corbicula in the lahe is not rapid and secondly, the alteration of the aquatic habitat by FIIPP vill not be instantaneous. (c) " Control Studios on Corbicula for Steam-Electric Generating Plantc," L.B.Gosc, et al. See coction entitled " Description of the Biofoulind; Problem". " Asiatic Clams Cause Shutdown Of ANO - Unit 2," M. !!acnik, EEE, !!RC, p at 2, 3. Opinion of Jcff Alexander. (d) (See response to Interrogatory 20.) (e) Unknown at this time.

27. (a) Evaluation of the Applicants' methods for detectin:; the presence of corb'cula is incomplete at this tine. OCRE chould complei:e its evaluation within three weeks and a response will issue then.

(b)-(f) (See response immediately above.)

28. Robert Alexander, 2030 Portsmouth St. #2, Houston, TX 77093

("RA") !!r. Alenander is an instructor with the Houcton Independent School District. Jeff Alexandu.m 020 Vilmington Avc #H, Dayton, OH. ("JA") lir. Jeff Alexander is a student at the University of Dayton. Robert Warnehe, 3262 Branard #10, Houston, TX 77098. ("RU") I'.r. Warnehe is a student at the University of !!ouston. Susan Hiatt, 8275 !!uncon Road, !!cntor, OH M060 ("SH") !!c. iliatt is a free-lance roccarcher for OCRE. Dr. Albert Burhy, University of. Dayton, Dayton,' Ohio. ("A3") Dr. Durhy is a profcccor at the Univorcity of Dayton. ' !!ote : Initials for percons listed above used in Interrogatories below. 29. percon interrocatories information provided for RA all JA 20 - 27 11 A a-

e e

00. (continued) e person interrro atoric:

R'.; 20, 2G lE! l-5, 14, 10, 10 A3 20 30. Re pon=c is cano at that to Interrogatory 20 uith the omission of AD. 31. OCRE objects in part to thic Interro atory. OCEE trill indicate at this time that the scarch fer document tra: conducted in the cano correlative manner a found in its ro ponce to Interro atory 20. As to tihere caid scarches were conducted, CCRC feel: that infrin ;e too cloco upon the vorh-product doctrino. F. E. C. *). 20 (1000) and 10 C."? 2.740 (b)(2). This Intervonor believe: that dicelecure of those location: could reveal portion: of OCn2 Otrate ;/ and Ic;;al theory. 32.

one knotn of at this time.

Recucat for Production of Docu-ent: OCC*: is villing to produce for copyin n? of the a'orementioned docu-cnt at place: convenient to OCnE. I nespectfully submitted, I \\+

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? ', i u .-,s.. v ~. "obert Ale::ander OCnt Interin neprecentative 2030 Port nouth St. 32 , Hou= ton, ""*. 77000 AFFIDAVIT OF ROBERT ALEXA! DER I, Robert Ale:cander, having been duly sworn depoco and say that I have read these answers to Interrogatories filed by Applicant and that those an vers are true to the best of my knowledge and belief. _\\ ~ notert Ale::ander Sworn to before ne anI cubscribed in ny presence on the 3 day of.Iiovonber, 1981. [b M 82Mr:4-- !!otary Public CLARA H. CN.".D!its 12 Notary Public in auf for the State of Teus My Com:r.isA21 !as.aes.tont 25. INS _ ~ _ _ _ _ _ _ _ _ _ _ _ _ -

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... %~ E ' a,-- CERTIFICATE OF SERVICE 0EQ -3 P4 :58 " hic in to cortify that co?icc of the forc oin-CCR~ "c .30 AT*.licant=' Interronatorie: cnd ?.cque t for Production of Eocunents To 8.A A Intervonor Ohio Citizens For P.cc,oncible Cncr.y (."irst Oct) hcvc been:=crvpp,- u7on, the follottin-by.depocit in the United Stetcc r.cil, ::onta c.frcTd 5EP24c B 'e'dcy of I:cvenber,1931.

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'y a. t. m. & l 'k.., f.' nobert Ale::nnder SERVICE LIST Peter B. Bloch, Chairman Atomic Safety i Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20G55 Dr. Jerry R. Klein l Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Frederick J. Shon Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Charles A. Barth, Esq. Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jay Silberg, Esq. 1800 M Street, N.W. Washington, D.C.- 20036 e t =}}

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