ML20039E950

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Response to Requests for Admissions.Certificate of Svc Encl. Related Correspondence
ML20039E950
Person / Time
Site: Zimmer
Issue date: 12/31/1981
From: Conover K
CLERMONT COUNTY, OH
To:
ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY
References
NUDOCS 8201110648
Download: ML20039E950 (18)
v • d • e


Text

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/ RELATED CORRESPONDENCE UNITED STATES OF AMERICA rnr ut: ..

NUCLEAR REGUIAIORY CCM41SSION '_"9-12 JAN -7 p4 :37 In 'Ihe Matter Of:

  • DOCier NO. 50-358

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'IEE CINCINNATI GAS & ELECI'RIC

  • OI7iG~igi's..

00Cidi SRM;0d CCMPMW, et al.

(Wm. H. Zimmer Nuclear Power Station) Q-r ' ,

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CImKNr COUNTY'S RESPONSE 'IO ZAC-ZACK'S -

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REQUESTS FOR AINISSIONS SUBMI'ITED 'IO CLEFMONT 00 UNIT ' . :,'l N. .v,

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TheinformationformingthebasisforthisresponsetotheatAched~~~

Requests for Admissions was obtained frm, in part, the files of and with the assistance of, Stone and Webster Engineering Company, who assisted in the development of the Clermont County Radiological Emergency Response Plan.

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UNITED STATES OF AMERICA NUCLEAR REGULA'IORY CQ+11SSION A'IrJMIC SAFTIY AND LICENSING BO3D In 'Jhe Matter Of:

  • DOCKET No. 50-358-OL

'ITE CINCINNATI GAS & ELECTRIC

  • C m PANY, et al. RESPONSE 'IO REQUEST R MSSM (Wn. H. Zinsner Nuclear Power Station)

I i RESPONSE OF CIERMJt1T COUNN 'IO RECUEST FOR ADMISSIONS OF

. INTREVENOR ZIMEk AREA CITIZENS-ZIbNER AREA CITIZENS OF KENIUCKY l

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1. The village of Felicity, including the schools located within the Felicity-Franklin School District, and the emergr.ncy response groups of the Felicity-Franklin police, fira and life squad, is provided telephone service by General Telephone Systsm.

! A WITTED.

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2. Any telephone call frcrn Felicity, Ohio to Batavia, Ohio, is a toll, long dis-tance, telephone call.

ArMITTED.

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3. Any telephone call from Batavia, New Richmond, Amelia, Mt. Carmel, or Withams-ville, Ohio to Felicity, Ohio, is a toll, long distance telephone call.

ADMITTED.

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4. Any telephone call between the Superintendent of the Clermont County Bmrd of Education or the Clermont County EOC to and frcm the Superintendent of the Felicity-Franklin School District is a toll, long distance, telephone call. ,

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ADMITTED.

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5. %e Superintendent of the Felicity-Franklin School District has three trunk lines for in-caning and out-going telephone calls to the Felicity-Franklin Superinten-tent's office.

DENIED 'IO 'IHE EXTENI' THAT THIS PEQUEST REFERS 'IO " TRUNK LINES."

THE SPECIFIC TERMINOLOGY FDR THESE LINES IS " SERVICE LINES."

6. The Superintendent of the Felicity-Franklin School District is possessed of only telephone cmmunications to school bus drivers of that school district not on school site at the time that it is necessary to suninon school bus drivers to the Felicity-Franklin School site for evacuation of pupils.

. ADMI'ITED.

7. We telephone system is use at the New Richmond School District and the bethel-Tate School District is Cincinnati Bell Telephone System.

ADMI'ITED. ~

8.

We Superintendent of the Bethel-Tate School District has two telephone trunk lines for in-caning and out-going telephone calls to the Bethel-Tate Superintendent's office.

DENIED 'IO 'IHE EXTENI' THAT THIS REQUEST REFERS'IO " TRUNK LINES.

'IEE SPECIFIC TERMINOLOGY FOR THESE LINES IS " SERVICE LINES."

9.

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% e Superintendent of the Bethel-Tate School District is possessed of only

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telephone cm munications to school bus drivers of that school district not on school i

site at the time that it is necessary to suninon school bus drivers to the Bethel-Tate School site for evacuation of pupils.

l ADMI'ITED.

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10. The Superintendent of the New Richmond School District has four telephone trunk lines for in-cczning and out-going telephone calls to the New Richmond Superin-l tendent's office.

DDJIED 'IO THE EXTH7T THAT THIS REQUEST REFERS 70 " TRUNK LINES."

711E SPECIFIC TERMINOIDGY FOR THESE LINES IS " SERVICE LINES."

11. The Superintendent of the New Richnond School District is possessed of only telephone ccmunications to school bus drivers of that school district not on school l

site at the time that it is necessary to sunnon school bus drivers to the New Richmond School site for evacuation of pupils.

l AINI'ITED.

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12. There are no dedicated telephone lines and servicing the Superintendents of f Clermont County, Felicity-Franklin, Bethel-Tate and New Richmond School Districts.

AIMITED.

13. New Rich:rond School District as 2,562 students and 17 buses.

DENIED. (SEE RESPONSE TO ZAC-ZACK'S INTERROGATORIES NO.105 and 106.)

14. Each school bus for the New Richmond School District has a seating capacity l for 60 students. .

l DDJIED. (SEE RESPONSE 'IO ZAC-ZACK'S INTERROGATORIES NO.105 and 106.)

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! 15. Bethel-Tate School District has 1900 students and 12 buses.

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l DENIED WITH REGARD TO THE NUMBER OF STUDENIS. AINITTED WITH REGARD 10 THE NI.NBER OF BUSES. (SEE RESPONSE TO INTREVENOR ZAC-ZACK'S INTERROGA7ORIES NO.105 and 106.)

l (3)

16. Each school bus for Bethel-Tate School District has a seating capacity for 60 students. -

DENIED. (SEE RESPONSE 'IO ZAC-ZACK'S IhTERROGA'IORIES NO.106.)

17. Potassium iodide is a blocking agent of the thyroid gland to reduce absorp-tion of radioactive materials.

AR11TTED 'IO THE EXTENT THAT POTASSIW1 ICDIDE IS A BIOCKING AGENT OF THE '111YROID GLAND 'IO REDUCE ABSORPTION OF PADIQACTIVE IODINE.

18. Potassium iodide, if administered within two hours of exposure to radioactive materials, will substantially reduce in-take by the thyroid gland of such reterials.

DENIED.

19. Administration of potascium iodide two or more hours after exposure to radio-active materials is 50 per cent effective.

DENIED.

20. Children under the age of 13 years, pre-puberty, are susceptible to acceptance and retention of radioactive materials by the thyroid gland.

REASONABLE INQUIRY HAVING BEEN MADE BY Rt1ERENCE 'IO U.S. EPA DOCUMENT 510/1-75-001. 'IllIS INFORMATION IS NOT KNOWN OR READILY AVAILABLE OR OBTAINABLE AND IS INSUFFICIENT 'IO FOPM A BASIS 'IO EITHER AD1IT OR DENY

'I1115 REQUEST FOR ADMISSION.

21. No school bus Ecssessed by any school district located in Clernont County, Ohio, is equipped with a two-way radio system.

ADMITTED.

(4)

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22. School buses possessed by the Bethel-Tate and New Richmond, School Districts are in the control of school bus drivers and parked at locations other than the schools i

i within each district during the course of a school day.

ADMITIED IN PART AND DENIED IN PARP. SOE BUSES ARE PARKED AT THE SCHOOLS.

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23. Monitoring of evacuees at reception sites, or centers, is to be acccrplished
within twelve hours of the evacuee's arrival at such site.

l ADMITTED.

24. During the presence of a contaminated evacuee at a receptior site, or center,

,, and before monitoring, that contaminated evacuee will contaminate the site and those evacuees and Emergency Response personnel present at such site.

DENIED. PROVISIONS EXIST EDR THE SEGREGATION OF SUCH PERSONS.

! 25. Section 311.07, Revised Code of Ohio, provides for the powers and duties of a i

i county sheriff in the State of Ohio.

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l ADMITIED IN PART AND LENIED IN PART. PGERS AND DUTIES OF A COUNTI SHERIFF ARE PROVIDED FOR IN OTHER SECTIONS OF THE OHIO REVISED CODE.

SEE RESPONSE 'IO ZAC-ZACK'S INTERROGP. TORY NO.187.

26. The Clermont County F;nergency Response Pla.% October,1981, provides that the Sheriff of Clermont County, Ohio, shall direct and control local police, fire and life squads of those agencies listed in said plan both as to plume exposure response and as to reception site response.

AEMITTED IN PART AND DENIED IN PART. THE CLERONT COUNIY EMERGENCY RESPONSE PIAN PROVIDES THAT IOCAL POLICE, FIRE AND LIFE SQUAD SHALL l l ALSO BE UNDER THE DIRECTION AND CONTROL OF THEIR PESPECTIVE CHIEFS AND SUPERIOR OFFICERS.

(5)

27. Section 311.07, Revised Code of Ohio, provides that the Sheriff of Clermont i

County, Ohio, may call upon the sheriff of any adjoining county, the mayor or chief I l

executive of any municipal corporation within his county or adjoining counties, and I the chairnan of the board of township trustees within his county or adjoining county, to furnish police and fire protection personns1 and equipment as may be necessary to I

preserve the public peace and property in the event of riot, insurrection or invasion.

l l A MITIED.

28. An emergency at the Zimmer Station is not a riot, an insurrection or an inva-sion.

ADMITIED.

29.

'Ihe Clermont County Emergency Plan, October,1981, provides no legal author-ity for the Sheriff of Clernent County, Ohio, to direct and control local police, fire l

l and life squad personnel as provided in said plan.

l OBJECTIW. SAID REQUEST mR AMISSION CALIS mR A LEGAL CCNCLUSION.

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30. S w tion 311.07, Revised Code of Ohio, does not provide power to the Sheriff of Clernont County, Ohio, to direct and control village and township police, fire and 3 ife squad personnel.

ORIECI' ION. SAID RD2UEST m R ADMISSION CALLS m R A L E AL CONCLUSION.

31. Section 4501.01(b), Revised Code of Ohio, defines a motor vehicle as any vehicle propelled or drawn by power other than muscular oower or power collected from overhead electric trolley wires, except motorizec' bicycles, road rollers, traction engines, power shovels, power cranes, and other equipment used in construction work and l '

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not designed for or employed in general highway transportation, well drilling machinery, ditch digging machinery, farm machinery, trailers used to transport agricultural produce or production materials.

AIMITTED.

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f 32. Section 4501.01(I), Revised Code of Ohio, defines nutor bus as any notor I

vehicle having notor power designed and used for carrying more than nine bassengers.

l l ADMITTED 'IO THE EXTENT THAT MOIOR BUS IS DEFIN1:D UNDER STfIGJ l

j 4501.01 AS ANY FOIOR VErlICLE HAVING bOIOR POWER DESIGNED AND USED FOR CARRYING FORE THAN NINE PASSE %ERS.

33. Section 3313.173, Revised Code of Ohio, provides that a board of education of any city, exempted village, county, local, or joint vocational school district nay expend district funds to obtain one or nore motor vehicles as defined in Section 4501.01, Revised Code of Ohio, by purchase or lease, and except as provided in Section 3327.14, ,

Revised Code of Ohio, any motor vehicle so obtained shall be used solely for school pur-I poses.

ADMITTED 'IO THE EXTENT THAT THAT SPECIFIC SECTION PROVIDES AS STATED

'IREREIN. OTHER SECTIONS OF TIIE RE/ISED CODE PROVIDE FOR OIRER PER-MISSIBLE USES.

34. Section 3327.14, Revised Code of Ohio, provides that the board of education of any school district that owns or operates buses for transporting pupils may contract under lease agreement with a municipal corporation or a public or nonprofit private l agency or organization delivering services to the aged, to make available one or note l

of the district's buses or other vehicles to be used for transporting persons 60 years of age or older and the board of the district may contract with any group, organization, L

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or other entity engaged in adult education activities.

ACHITTED 'IO DIE EXTENT 'IEAT THAT SPEIFIC SECTION PROVIDES AS STATED DEREIN. OIEER SECTIONS OF THE REVISED CODE PROVIDE FOR OIEER PER-MISSIBLE USES.

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35. The buses present in each school district in Clernont County, Ohio, are owned

, and operated by the boards of education of each district.

OBJrTTION, ON DE GROUNDS THAT HIIS REQUEST FOR AINISSION ASKS FOR A LEGAL CONCLUSION.

36. No board of education has any contract or ageement with any group, including

, the Clernent County Ccomissions, the Sheriff of Clermont County, or the Disaster Ser-vices Agency of Clermont County, to provide buses for the transportation of persons age 60 and older or adult education groups as the same would apply to the Clernont anergency Plan, October,1981.

DE INFORMATION OR ENCh1 EDGE WITHIN ME POSSESSION OF MID INDIVIDUAL RES-PONDING HEREIO IS INSUFFICID7T 'IO ADMIT OR DENY U1IS REQUEST FOR ADMISSION; REASONABLE INQUIRY HAS BEEN MADE AND DE,INFORMATION IS NOT KNOWN OR READILY AVAILABLE OR OBTAINABLE.

37. The Clermont County Emergency Plan presents no legal authority for the use of school buses for the transportation of members of the general public and the transporta-tion of the general public during a Zinmer Station emergency is not a school purpose.

OEUECTION, ON MIE GROUNDS THAT MIIS REQUEST FOR AEMISSION ASKS FOR A LEGAL CONCLUSION.

38. 'Ihe Clernont County pupulation in Designated Sectors SSE(H) and SE(G) (as i

designated by the Clermont County Radiological Dnergency Response Plan, hereinafter i referred to as the Clernunt Plan), consists of a permanent population of approximately ,

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800.

DD4IED.

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I 39. 'Ihe evacuation routes designated for the Clermont residents described in i

Request #1 consists of the following alternatives:

(a) that population shall proceed in an easterly direction from the Zimer Station on a major evacuation route of U.S. 52, through Wash-ington and into Franklin Townships, to S.R. 133, the junction of which is not an access control site and then proceed in a northerly direction on S.R. 133, a distance in excess of ten miles to S.R. 125 l at Bethel, Ohio, at which point they are emerging frm the plume l exposure area: or l

(b) they may proceed northerly on S.R. 133 to the Village of Felicity and then proceed on S.R. 222 to S.R. 232 to S.R. 125 at Bethel which route contains an approximate distance of eleven miles on U.S. 52 and an approximate distance of 20 miles on S.R.s 133 222, and 232 until

, said evacuees would be beyond a ten mile radius frm the Zimrer Sta-tion; or (c) alternatively after traveling on S.R. 222 to remain on that route to its intersection with S.R. 125 near Bethel which evaluation route contains a distance of up to 29 miles of travel until said evacuees are beyond a ten mile radius from Zinmer.

'IHE EVACLTATION ROLITES DESCRIBED THEREIN ARE NOT EXCLUSIVE.

l 40. The popylation east of the access control point on U.S. 52 0.25 mile east of S.R. 133, which involves the populations situated east of S.R. 133 and the Village of l Utopia and approximately 40 roads serving residents in the Designated Sections SSE(H),

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l SE(G), E(E), ENE(D), AND NE(C) of the Clermont Plan, for purposes of evacuation must l either proceed into the plume area by proceeding by roadways intersections with S.R.

133 or by following county and township roads to S.R. 125 west of Bethel, or proceeding l

directly into Brown County.

AINITTED IN PART AND DENIED IN PART 'IO 'IHE EXTENT 'INAT OINER T(XJrES ARE AVAIIABLE FOR EVACUATION.

41. 'Ihe Clermont population in Designated Sectors (portions) E(E), ENE(D), NE(C),

(9) _ - -

I NNE(B) and N(A) of the Clermont Pltn consists of populations of Monroe End Washington Townships of approximately 1,639 permanent residents.

DENIED.

42. The Clermont population described in the preceding Admission are to be l evacuated along the following alternative routes in the Clermont Plan:

(a) one, a southernly direction to U.S. 52 towards the Zimmer Station and thence west on U.S. 52; or l (b) they must proceed in a northwesterly direction on S.R.132

! thence north on S.R. 132 to S.R. 125; or

, (c) they must proceed in a northeasterly direction on S.R. 222, l thence northerly on S.R. 222 to S.R. 125.

l ADMIT 11D IN PART AND DENIED IN PART 'IO THE EXTENT THAT OTHER RXTTES ARE AVAIIABLE FOR EVACUATION. -

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43. The roadways described in the proceeding Admission consists of two state roadways and approximately 38 county and township roadways. These county, township, t

and two state roadways for travel to an evacuation route are narrow, winding, and hilly at many points.

OBJECTION. SAID REQUEST FOR AD4ISSION REQUIRES A SUBJTTIVE OPINION AND IS NOT AN APPROPRIATE RESPONSE BY WAY OF REQUEST FOR ADMISSION.

l 44. With respect to the Clermont population in Designated Sectors N(A), NNW(R) l l

and NNE(B) of the Clermont Plan, the approximate permanent population is 10,596.

DENIED.

45. 'Ihe evacuation routes for the population desciribed in the preceding Admission consists of one state roadway and 27 county and townshio roadways.

DENIED, 'IO THE EXTENT THAT OTHER STATE AND COUNTY ROUTES EXIST.

(10)

46. %e roadways for travel to an evacuation route described in the preceding Admission are narrow, winding, and hilly in many parts.

OBJECTIQJ. SAID REQUEST NR A31ISSION REQUIRES A SUELTECTIVE OPINION AND IS 1CT AN APPROPRIATE RESPONSE BY WAY OF REQUEST mR A&iISSION.

47. We evacuation time estimates for evacuation of the Clernont population in I

the Clernont Plan ranging frcxn 1.0 to 3.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, is the calculated time based upon conditiens which would not include:

(a) roadway blockage due to vehicular mishap; (b) weather circumstances of the area which includes snow, ice and flooding; (c) possibilities that portions of the population will have inadequate fuel for their evacuation vehicle; (d) possibilities that persons in single vehicle families will be in the evacuation area without access to a vehicle.

(e) road intersections; (f) roads less than 12 feet in width; (g) roads without berm or shoulder.

DENIED.

48. With respect to fire squads in Clermont County, Clernont County has volunteer fire squads only.

DENIED.

49. With respect to life squads in Clermont County, Clernont County has only volunteet life squads.

DENIED.

50. The only Clernont County volunteer life squads which have trained paramedics are Coshen and Miamiville.

(11)

DD4IED. (SEE ZAC-ZACK'S INTERROGA'IORIES 'IO CLERMNT COUNTY, 36) .

51. At flood state (Ohio River crest of 53 feet):

(a) U.S. 52, approximately one-fourth of a mile north of the Village of Neville, is under water and impassable as is Neville Spur and Maple Creek Road for an approximate distance of one-half mile; (b) Near the Village of bbscow, just south of S.R. 743 by several feet, U.S. 52 is under water and irtpassable for an approximate dis-I tance of one-half mile which would include Ray Run; (c) On either side of U.S. 52 at the intersection of Laurel-Moscow Road for a distance of approximately one-half mile, U.S. 52 is under water and impassable.

NEI'IHER ADMITTED OR DFNIED ON 'IHE BASIS 'INAT THE INFOR4ATION KNOWN OR READILY AVAIIABLE OR OBTAINABLE IS NOT SUFFICIENT 'IO FORM A 3 ASIS 'IO ADMIT OR DDJY AND REASONABLE INQUIRY HAS BEEN MADE.

52. At a 64 feet Ohio River crest the bridge over Little Indian Creek near Laurel-Moscow Road and U.S. 52 intersection, on U.S. is under tater and impassable.

NEI'IEER AD4ITTED OR DDJIED ON THE BASIS 'IEAT 'IHE INFORMATION KNOWN OR READILY AVAIIABLE OR OBTAINABLE IS NCTT SUFFICIDJT 20 FORM A BASIS

'IO AIMIT OR DENY AND REASONABLE INQUIRY HAS BEEN MADE.

53. At flood stage (Ohio River crest of 53 feet), the following are under water and impassable:

(a) U.S. 52 at the Village of Point Pleasant, including the intersec-tion of U.S. 52 and Indian Road, the intersection of U.S. 52 and S.R.

232 for an approximate distance of one-half mile; (b) from an 1 including Clermontville Road and its intersection of U.S. 52 and portions of Clermontville Road approximately one-half mile to the north; (c) from a distance of approximately one-fourth mile south of the Village of New Richmond to approximately one-fourth mile south of the intersection of Bethel-New Richmond Road and U.S. 52 along U.S. 52; (d) the streets of the Village of New Richmond within 200 yards of U.S. 52 and to the west of U.S. 52:

(e) the bridge located at Fagins Run Road within 50 feet of S.R.132; (12)

NEITHER AINI7TED OR DENIED ON THE BASIS THAT THE INFOR>RTION KNOB.N OR RFADILY AVAIIABLE OR OBTAIMABLE IS NOT SUFFICIENT 70 FORM A BASIS 70 AEMIT OR DENY AND REASONADLE INQUIRY HAS B E MADE.

54. During flooding of the Ohio River at a crest of 80 feet the following in Clermont County are under water and impassable:

(a) U.S. 52 frm approximately one mile east of the Village of Neville t

to the west and north to within approxircately 200 feet to the entrance of the Zimer Station and within 200 feet to the north of the entrance of the Zimer Station and continuing through the villages of Point Pleasant and New Richnond; (b) U.S. to the northwest of New Richmond; (c) the intersections of U.S. 52 and Maple Creek Road, S.R. 743, laural-Moscow Road, Indian Road, S.R. 232, Clernantville Altman Road, and Frank Willis Memorial Road.

NEIT.'3ER ADMITTED OR DENIED ON THE BASIS THAT THE INFORMATION KNOW OR READILY AVAIIABLE OR OBTAINABLE IS NOT SLTFICIENT TJ FORM A BASIS

'IO AIMIT OR DENY AND REASONABLE INQUIRY HAS BEEN MADE.

55. The schools in the New Richnond and Bethel-Tate School Districts of Ohio and the Campbell County School District of Kentucky have no means of comunications to bus drivers while the drivers are enroute to or frm school.

ADMIT.

56. The buses utilized for student transportation of pupils in New Richnend and Bethel-Tate School Districts of Ohio and the Campbell County School District of Kentucky cre generally maintained by their drivers at the driver's residence or other parking area and the buses are parked during the school day off-site of the affected schools within the respective districts.

ADMI'ITED IN PART AND DENIED IN PART. BETHEL-TATE SCHOOL DISTRICIS PROVIDE FOR 71!E PARKING OF SOME BUSES ON SITE. INFORMATION WITH REGARD 10 CAMPRF71 COUNIY SCHOOL DISTRICTS OF KENIUCKY IS !CT AN APPROPRIATE REQUEST DIRECTED

'IO CLUNONT COUNTY.

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57. With rapect to the preceding Admission, the New Richmond, Bethel-Tate, )

l and Campbell County School buses are located generally during the school day at sites l frczn 5 to 15 miles from the schools with they serve.

AmITIED IN PART AND DENIED IN PAP:P. REIEEL-TATE SCHOOL DISTRICIS PROVIDE FOR THE PARKING OF SWE BUSES ON SITE. INFORMATION WIRI REGARD 'IO CAMPRFTL COUNTY SCHOOL DISTRICTS OF KBfrUCKY IS NOT AN APPPDPRIATE REQUEST DIRECTED 'IO CLFRENT COUNTY.

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58. With respect to the various state and county radiological energency plans, in the event an evacuation of areas surrounding the Zi.'mer Station is necessary, the evacuees are to be taken to relocation centers. No prcwisions exis't in any of the plans for the inmediate screening and segregation of those persons to have been expose <* to and contrainated by radiation.

DENIED.

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VERIFICATION STATE OF CHIO )

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COUNIY OF CLERMONT) i I

Kenneth Conover, being first duly sworn, states that he is the Director of the Disaster Services Agency, of Clermont County, Ohio, that he has been involved in j the preparation of the Clernont County Radiological Dnergency Response Plan and that 1

he has been duly authorized to execute, verify and file the foregoing document, i

"Clermont County's Response to ZAC-ZACK'S Request for Admissions", that he has read l

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. the contents of the same and that the statements contained therein are true and correct to his best information, knculedge and belief.

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14, enneth Conover l

Subscribed andsworn to before me this 3/d day of recember,1981.

f r

Y f) Notary Public aAc1/D1L b M A.. i l

I LNITED STATr'S OF AMERICA - NUCIEAR REIXIIKIORY OCH4ISSION s

  • l In.'Ihe Matter Of:
  • DOCKET NO. 50-358 ,

1 

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               'IEE CINCINNATI GAS & ELFLTRIC COMPANY, et'al.                                           .

(Mn. H. Zimner Nuclear Power Station) . CERTIFICATE OF GERVICE I hereby certify that a copy of this Response to Admissions was served upon 

      ,           Andrew B. Dennison, Counsel for Zac-Zack, and John Woliver, by personally delivering a copy to them on this 31st day of December,1981, and to all other parties by posting in the U.S. mail, ordinary mail service, on the                                 day of January, 1982.

John A. Frye, III. Esq. Chairman, Atomic Safety and Choirman. Atomic Safety Licensing Appeal Doard Panel and Licensing Board .- U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 l Wachington.'D.C. , 20'555 j i s- * 

                                                            ,           Chairman, Atomic Safety and i

Dr. Frank F. Hooper, Member

  • Licensing Board Panel i Atomic Safety and Licensing U.S. Nuclear Regulatory
;         . Board         -

Cormnission 4 School of Natural Resources Washington, D.C. 20555 University of Michigan Ann Arbor, Michigan 48109 Charles A. Barth, Esq. ^ 

        *Dr. M. Stanley Livingston,                                '   Counsel.for the NRC Staff Atcmic Saf~ety and Licerising Office of the Executive Legal Director Coard                  -
                                              ..                       U.S. Nuclear Regulatory 1005.Calle Largo l

Commission i 

; , Santa Fe, New Mcgiic'o                           87501',          , Washington, D.C.               20555
   , Richard S. Salzman, Esq. -                                        William J. Moran, Esq.

Chairman, Atomic Safety ,and, General Counsel c~ Licensing Appeal Board Cincinnati Gas & Electric D.S. Nuclear Regulatory Company 3 Commission . Post Office i Box 960 

      ' Washington, D.C.                 20555                   -

Cincinnati, Ohio 4520_1, __

Dr.' Lawrence R. Quarles Mr. Chase R. Stephens

  • Atomic Safety and Licensing Docketing and Service Branch Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission  ;

Conunission Washington, D.C. 20555 l Washington, D.C. 20555 Andrew B. Denison, Esq. John D. Woliver, Esq. Attorney at Law Clermont County Community 200 Main Street Council Batavia, Ohio 45103 Box 181 Batavia, Ohio 45103 James R. Feldman, Jr., Esq. 216 East Ninth Street David K. Martin, Esq. Cincinnati, Ohio 45202 Assistant Attorney General Acting Director Deborah Faber Webb Division of Environmental Law 7967 Alexandria Pike Office of Attorney General Alexandria, Kentucky 41001 209 St. Clair Street Frankfort, Kentucky 40601 Troy B. Conner and Mark J. Wetterhahn Conner & Wetterbahn 1747 Pennsylvania Avenue, N.W. Washington, D.C. 20006 Lawrence R. Fisse Assistant Prosecuting Attorney 462 E. Main Street Batavia, Ohio 45103 (513) 732-7313 

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