ML20039E961
| ML20039E961 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 01/05/1982 |
| From: | Martin D KENTUCKY, COMMONWEALTH OF |
| To: | MENTOR, KY |
| References | |
| NUDOCS 8201110662 | |
| Download: ML20039E961 (112) | |
Text
{{#Wiki_filter:su iT!so CO tiriK:OWm C%?;E.?? i r,)gz-UNITED STATES OF AMERICA '82 JMI -7 P L :37 NUCLEAR REGULATORY COMMISSION A c7P.: E 4:.:~ C3C u , ;3 ::., ,
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In the Matter of )
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The Cincinnati Gas & ) Electric Company, et al ) Docket No. 50-358 W , K s
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(Wm. H. Zimmer Nuclear Power Station)
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R J4p' COMMONWEALTH OF KENTUCKY'S OBJECTIONS TO THE FORMAL DISCOVERY REQUESTS OF THE CITY OF MENTOR h'
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' i The Commonwealth of Kentucky hereby object U0 the _
formal discovery requests of the City of Mentor served December 15, 1981, for the reason that the City of Mentor is not entitled to formal discovery against the Commonwealth. The reasons for the Commonwealth's ob'jections are the same as those set out in the Commonwealth's objections to the formal discovery requests of ZAC/ZACK, served December 23, 1981. Additionally, the Commonwealth points out the absurdity of . requesting formal admissions from a nonparty. Whatever the Commonwealth would admit or deny would not bind the Applicants or the NRC Staff, who are the only participants likely to litigate the City of Mentor's contentions in opposition to the City of Mentor. Whatever the Commonwealth would admit or deny would not therefore narrow the scope of the evidence required to be heard. Accordingly, the purpose of. formal 9563 5
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admissions would not be served by requiring the Commonwealth to answer requests for admissf.ons. As in the case of the earlier filed ZAC/ZACK interrogatories. however, the Common-wealth has attempted to provide on an informal basis the information requested by the City of Mentor. Enclosed are } informal responses to the City of Mentor's interrogatories prepared on behalf of the Commonwealth of Kentucky. As to the admissions requested by the City of Mentor, it appears that only the sixth is a completely true statement at the ,present time. As to Request for Admission 3, not all schools have written SOPS at this time. These responses are offered for informational purposes to assist the parties and the Licensing Board rather than as formal responses to discovery. They will not be supplemented as requested in Mentor's interrogatories. Even formal interrogatories ordinarily are not subject to supplemen- . tation. See 10 CFR 2.740(e). The Commonwealth, for the foregoing reasons, is entitled to and moves for a protective order concerning the discovery requests of the City of Mentor. Respectfully submitted, STEVEN L. BESHEAR ATT EY GENERAL bk I BY: DAVID K. MARTIM l ASSISTANT ATTORNEY GENERAL COUNSEL FOR COMMONWEALTH OF KENTUCKY l
gg a,en m:0rCr CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Commonwealth of Kentucky's Objections to the Formal Discovery Requests of the City of Mentor has been mailed to the following this 5th day of January, 1982: Andrew B. Dennison 200 Main Street Batavia, Ohio 45103 r James H. Feldman, Jr., Esq.
- Fifth Level 216 East Ninth Street Cincinnati, Ohio 45202 4
George E. Pattison, Esq. 462 E. Main Street Batavia, Ohio 45103 John D. Woliver, Esq. P.O. Box 47 550 Kilgore Street Batavia, Ohio 45103 William J. Moran, Esq. General Counsel Cincinnati Gas & Electiic Co. E9,fEJ/i P.O. Box 960 - ' ' ' Cincinnati, Ohio 45201 i Atomic Safety & Licensing Board Panel T2 JAN -7 P4 :38 U. S. Nuclear Regulatory Commission d Washington, D. C. 20555 07-K E . : 5EU.i. - ) DCchET. :G & SE.-v Atomic Safety & Licensing Appeal Board 5'*=N
- U. S. Nuclear Regulatory Commission
{ Washington, D. C. 20555 Troy N. Conner, Esq. Conner & Wetterhahn 1747 Pennsylvania Avenue N.W. Washington, D. C. 20006 Charles A. Barth, Esq. U. S. Nuclear Regulatory Commission Room MNBB 9604 7735 Old Georgetown Road Bethesda, Maryland 20014 i l I . .. . _ _ _ . ..
Deborah Webb' 7967 Alexandria Pike Alexandria, Kentucky 41001 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 - Dr. M. Stanley Livingston, Member ! Atomic Safety and Licensing Board 1005 Calle Largo Fante Fe, New Mexico Dr. Frank F. Hooper, Member Atomic Safety & Licensing Board School of Natural Resources University of Michigan Ann Arbor Michigan 48109 John H. Frye, III Chairman, Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 - i David K. Mdrtih ' Assistant Attorney Gener.al Counsel for Commonwealth of Kentucky i I
,: ' o RELATED C0F223FG3:D_m,'m D00ICT I;!!!.i!E.1 PRCD. & UTIL Ft.C.kl..),, ..
Interrogatory #1 State whether or not the Commonwealth has Standard Operating Procedures for Esergency Operations Centers. If so, attach a copy. If not, attach those parts of the procedures in draft or final form which are written and give the anticipated date of completion for those parts not written.
Response
Yes, copies are available at Kentueky Disaster and Emergency Services' office in Frankfort, Kentucky. m';T-:Ert-
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Interrogatory #1a List all state and county officials who do have or will have a copy of the above Standard Operating Procedures and state where such copies of { these procedures will be physic:lly located. l Response At the present time, the distribution list has not been finalized. The Sta te EOC and Campbell, Pendleton, and Bracken County EOCs have each received draft copies of the procedures and have been distributed among select members of the EOC staff. t l 1 i l I i 1 s i i i s i i a 1 ' l , 1 l 4 i l l l
Interrogatory #2 State whether or not the Commonwealth has Notification Standard i Operating Procedures. If so, attach a copy. If not, attach those parts ! of the procedures in draft or final form which are written and give the anticipated date of completion for those parts not written. -
Response
Yes, copies are available at Kentucky Disaster and Emergency Services' office in Frankfort, Kentucky. e 9
1 Interrogatory #2a List all state and county officials who do have or will have a copy of the above Notification Standard Operating Procedures and state where such copies of these procedures will be physically located. , Response . At the present time, the distribution list has not been finalized. The State EOC and Campbell, Pendleton, and Bracken Count.y EOCs have each received draft copies of the procedures. t I i ,I , I i T i 4 j J l
Interrogatory #3 State whether or not the Commonwealth has a written completed list of those to be called in an emergency (disaster alert roster), with alternates pursuant to Notification Standard Operating Procedures. If so, attach a copy. If not, state the anticipated date of completion of such a list.
Response
A disaster alert roster has been completed, however as this list has I personal telephone numbers, some unlisted, it is not a public document and is not available for public inspection. 1 1 1 j f a I l l 't e 6 l l l
Interrogatory #3a State whether or not the Commonwealth has a Duty Officer Standard Operating Procedure. If so, attach a copy of such procedure. If not, attach those parts of the procedure in draft or final form which is written and give the anticipated date of completion for those parts not 4 written.
Response
Duty Officer Standard Operating Procedures are available for inspection i at Kentucky DES in the Boone National Guard Center in Frankfort, Kentucky. i 4 i
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4 Interrogatory #3b List all state and county officials who do have or will have a copy of the above Duty Officer Standard Operating Procedure. State where such copies of this procedure will be physcially located.
Response
This is not supplied to County officials. Kentucky DES personnel in the Frankfort Office have copies of the Standard Operating Procedures. 4 4 i i 1 } i I l i l 1 t I l 1 i i l 4 i j i I i l 6
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i Interrogatory #4 i State what materials and equipment would be needed in order to implement Notification Standard Operating Procedures for Campbell, Bracken, and Pendleton Counties respectively. l Response , Refer to Annex C in the Kentucky Radiological Emergency Plan and the Bracken, Pendleton, and Campbell County Radiological Emergency Plans. J d t i 6
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Interrogatorv #5 ' With regard to the counties listed in Interrogatory four, state which items listed in answer to Interrogatory four each of the counties does not currently have and the purpose each item would serve in the event that Notification Standard Operating Standards were employed.
Response
All equipment in Interrogatory 4 will be available before the Zirer Nuclear Power Station begins commercial operation. i i i r 1 f 9 e 1 i 1 w s ed v s l I i i 1 9 s /
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Interrogatory #6 1 I State whether or not the Commonwealth has completed written School l Standard OperaGt;; Procedures. If so, attach a copy. If not, attach those parts of the procedures in draft or final form which are written and give the anticipated date of completion for those parts not written.
Response
The School Standard Operating Procedures for Bracken, Campbell' and Pendleton Counties, in their various stages of completion, are attached to the response to Kentucky ZAC/ZACK Interrogatory 128. The procedures I will be complete by the time Zinner goes into commercial operation. t t e O P 8N f I $ p-) 0 .
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Q j List al1 state and county officials who do have or will have a copy of l the abcve School Standard Operating Procedures and state where such
- copies of these procedures will be physically located.
Response . This information is not available at this time. Local distribution will be determined by local school officials. f 4
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Interrogatory 67 State what equipaent would be necessary to implement Standard Operating Procedures for schools in Campbell, Bracken, and Pendleton Counties, respectively. Ir. answer to this interrogatory distinguish between what equipment would be needed by the State and what equipment would be needed by each county. - Response , The equipment necessary to implement the School Standard Operating Procedures is specified within the procedures. This equipment will be used by county and school personnel. l D 1
4 Interrogatory #8 List which of the above items the State and each of the counties does not have and the intended purpose for each item in the event that Standard Operating Procedures for schools were employed in Campbell, Bracken, and Pendleton Counties, respectively. ,
Response
i ~ The appropriate agencies needing equipment to implement the School Standard Operating Procedures have or will have such . equipment by the time Zimmer goes into corsercial operation. The intended purpose for each item of equipment is specified within the procedures. i ) l 6 I I l + I 4 i O
Interrogatory #8a State the number of personnel each of the three counties would need to implement the standard operating procedure for schools and state what duty each would be assigned. Response l Unknown. The number of personnel needed to implement school standard I operating procedures varies according to the procedure implemented and the circumstances of the emergency. l i t l 1 l r i
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Interroaatory #8b State which of the above personnel would be volunteers.
Response
See Response to Interrogatory #8a. l I e 1
Interrogatory #9 State whether or not the Commonwealth has written completed standard operating procedures for activation of the Emergency Broadcast System. - 4 If so, attach a copy. If not, attach those parts of the procedures either in draft form or final form which are written and give the
. anticipated date of completion.
Response
; Standard Operating Procedures have been written for the activation of the Emergency Broadcari, System. A copy in draft form is available for inspection at the Kentucky Division of Disaster ana Emergency Services offices in Frankfort, Ky.
These procedures will ac completed prior to commercial operation of ZPS-1. , b i G i l
Interrogatory #9a List all state and county officials who do have or will have a copy of the above Standard Operating Procedures for activation of the Emergency Broadcast System and state where such copies of these procedures will be physically located.
Response
Officials identified in the draft procedures will have copies of these
! Procedures. Other officials who will have copies of the completed Procedures have not yet been identified. The physical location of the completed procedures has not been established.
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Interrogatorv #10 State whether or not the Commonwealth has standard operating procedures , for ' accident assessment. If so, attach a copy. If not attach those
, parts of the procedures which are written either in draft or final form t
and state the anticipated date of complecion for those parts not written.
Response
2 Kentucky has Standard Operating Procedures in draft form. A copy may be I inspected at the Kentucky DES offices in Frankfort. i l 3 e h . l t l l l 1
Interrogatory #10a l State whether or not the Commonwealth has a damage assessment form for use by the Radiation Control Board personnel. If so, attach a copy. If I not, attach those parts of the damage assessment form which have been written, either in draft or final form and state the anticipated j completion date for those parts not written. I
Response
The Standard Operating Procedures (SOP's) contain many forms for use in assessing the impact of a radiological release. A copy of the SOP's may be inspected at the Kentucky DES offices in Frankfort. 4 l ) i _ _ _ _ _ _ _ _ _ - - _ _ __ ___ me w
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i i l Interrogatory #10b State whether or not the Commonwealth has standard operating procedures for maintaining individual exposure records. If so, attach a copy. If not, attach those parts which are written, whether in draft or final form and state the anticipated date of completion for those parts not written. Response - The draft Standard Operating Procedures contain forms for maintaining individual exposure records. A copy of the SOP's may be inspected at , the Kentucky DES offices in Frankfort. t e e 4 0 1 1 l l l l I
1 Interrogatory # 11 State what equipment would be necessary in order for the Radiation Control Branch to do an adequate job of accident assessment including off-site dose projection and the collection of field radiological data in the event of a general emergency. Response ' i, The equipment necessary to perform accident assessment, including off-site dose projection and the collection of field radiological data, is listed in the Kentucky Radiological Emergency Plans for the Wm. H. Zimmer Nuclear Power Station and in the draft RCB Standard Operating Procedures. 1 4 j 1 1 4 1 i i 1 e i i
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Interrogatory #12 State which of the above listed items the Commonwealth does not have and ! the purpose each ites would serve in the event that an accident occurred.
' Response All equipment necessary for implementation of accident assessment will be received prior to commercial operation of ZPS-1.
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T l Interrogatory #13 State the number of personnel needed to carry out accident assessment l standard operating procedures and their respective duties.
Response
The Standard Operating Procedures are written in a flexible manner so that the number of persons required is not a fixed number. Instead the number can vary considerably, with many personnel trained in more than one function. t 1 e a i . ( 4 e 1 4
Interrogatory #14 How many people who are qualified to perform the above listed duties are 4 employed by the Radiation Control Branch presently?
Response
There are 3 Radiation Control Branch persons and 2 Kentucky DES persons qualified and assigned to carry out the functions at the Frankfort. EOC. There are 4 Radiation Control Branch persons assigned and qualified to carry out the functicas at the Field Radiological Center. It should be noted that the functions vary but are related and that many people are qualified for mare than one position and can fill in vacancies as needed. i o i L 3 e ) 1 l
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f Interrogatory #15 1 Assuming that more personnel are needed than what are presently employed, and that volunteers will be needed for monitoring and decontamination efforts, give a list of such volunteers and what training they have received. 1
Response
See the Commonwealth of Kentucky Response to ZAC/ZACK Interrogatories to 4 the Intervenor State of Kentucky (12-4-81) #19, #23, #26, #31. i I 1 i i i i 4 1 i l e 4
l Interrogatory #16 i l State whether or not the Commonwealth has standard operating procedures for Personnel Decontamination , and if so, attach a copy; if not, attach those parts of the procedure in draft or final form which are written, and
.gi ve the anticipated date of completion for those parts not written.
Response
, A draft copy of the Standard Operating Procedures for personnel decontamination may be inspected at the Kentucky DES offices in Frankfort.
Also, see response to ZAC/ZACK Interrogatory GJ't. ,- f fi ,) i i l 1 f J i t I l i d i l i 1 I 4 I
Interrogatory #17 State whether or not the Commonwealth has written completed standard operating procedures for Radiological Monitoring. If so, attach a copy. If not, attach those parts which are written, whether in draft or final form, and state the anticipated date of completion for those parts of the procedures not written. Nesponse I Kentucky has Standard Operating Procedures for radiological monitoring. A copy can be inspected at the Kentucky DES offices in Frankfort. 4 i ) ) J ) s 1, 1 i i I O
l i Interrogatory #17a State what equipment would be necessary in order for the Radiation Control Branch to do an adequate job of Radiological Monitoring for each
- classification of accident.
Response
The required equipment is identified in the Kentucky Radiological B.rgency Plan for the Mn. H. Zimmer Nuclear Power Station and the draft RCB Standard Operating Procedures. 4 I i 4 e 4 I i
1 Interrogatory #17b State which of the above listed items the Commonwealth does not have and the purpose each ites would serve in the event that an accident occurred.
Response
t The Commonwealth will have all required equipment prior to commercial operation of ZPS-1. e 1
Interrogatory #18 l l State whether or not the Commonwealth has written completed standard I operating procedures for Decontamination of Equipment. If so, attach a copy. If not, attach those parts which are written, whether in draft or final form, and state the anticipated date of completion for those parts of the procedures not written.
Response
A draft copy of the Standard Operating Procedures for decontamination of equipment may be inspected at the Kentucky DES offices in Frankfort.
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I Interrogatory #18a State what equipment would be necessary in order to implement the standard operating procedures for Decontamination of Equipment. i
Response
All equipment necessary to implement the procedures for decontamination of equipment are identified in the Kentucky Radiological Emergency Plan for the Wm. H. Zimmer Nuclear Power Station, the draft RCB Standard Operating Procedures, and local decontamination procedures. t o O e e s
j ! Interror,atory #18b State which of the above listed items the Conunonwealth does not have and the purpose each item would serve in the event that an accident occured.
Response
The Commonwealth will have all required equipment prior to commercial operation of ZPS-1. L t 6 9
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Interrogatory #19 State whether or not the Commonwealth has written completed standard operating procedures for Ingestion Pathway Protective Actions Recommendations. If so, attach a copy along with tables 305-4 and 305-5. If not, attach those parts which are written whether in draft or final form and state the anticipated date of completion for those parts of the procedures not yet written. Tables referred to are from the Kentucky State Plan. I Response A draft copy of the Standard Operating Procedures for Ingestion Pathway Protective Actions may be inspected at the Kentucky DES offices in Frankfort. l
Interrogatory #19a State what equipment would be necessary in order to implement the standard operating procedures for Ingestion Pathway Protective Actions Recommendations.
Response
All equipment needed to implement the procedures for Ingestion Pathway Protective Actions Recommendations are identified in the Kentucky Radiological Plan for the Mn. H. Zimmer Nuclear Power Station and the draft Standard Operating Procedures on file at the Kentucky DES. t ) 1 e i I 5 1 4 5 4
Interrogatory #19b State which of the above listed items the Commonwealth does not have and the purpose each item would serve in the er;nt that an accident occurred.
Response
The Commonwealth will have all necessary items prior to commercial operation of.ZPS-1. I 1 i -I l <4 l l 4 i J J t ( 4 9
Interrogatory #20 State whether or not the ~ Commonwealth has written completed standard
- operating procedures for the use and distribution of Potassium Iodide.
If so, attach a copy. If not, attach those parts which are written whether in draft or fimal form and state the anticipated date of 1 . completion for those parts of the procedures not written. - Response , The Kentucky Radiological Emergency Plan for the Wm. H. Zimmer Nuclear Power Station states policy and discusses the distribution and use of i potassium iodide. Procedures have not been completed and are under i development. 1 9 i A b d J .i I l i h d
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Interrogatory #21 - . r' Other than the standard operating janocedures already inl;uired of in t'be . ,. above interroge tories ,. [does the Commonwealth have any' other completed' #
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written standard operating procedures, - including Radiation ' Cont.rol ;.' . Branch standard operat. ins procedures numbers 301 sud 302. ~If se,' attach ,. . " ' a copy. Numbers are i'rco the Kentucky State Plan.
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Any other additional s'candard Operating . Procedures are in a draft f o'em , and copies may be inspecte'd at the Kentucky DES offices in frankfort.
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~ If the answer to the above interrogatory is no, does the Commonwealth I have any uncompleted standard operating procedures. If so, attach a
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copy of those parts which are written, whether in draft or final fons, and state the anticipated date of completion of those parts unwritten. l t Response All Standard Operating Procedures are in a draft form, and copies may be inspected at the Kentucky DES offices in Frankfort. l l
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i Interrogatory #23
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, . State whether standard operaEing procedures will be developed for use by.
. agricultural- service coordinators to aid farmers with, and inform farmers of the following problems: the manner and means by which poultry n
and livestock alternate feed source (feed kept under cover) will be obtained, maintaused and supervised; the availability and distribution of uncontaminated feeds for poultry and livestock; the means and manner by which livestock shall be sheltered; the proper means of cleaning, storing and preservation of poultry and livestock feeds; methods and directions fon decontreinsting livestock and poultry and their i respective feed; and if such standard operating procedures already k exist, attach a copy.
Response
j See response to ZAC/ZACK interrogatories 79 and 80. .
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J Interrogatory #24 i State the water source for each municipality within the 50 mile { Ingestion Pathway Emergency Planning Zone in Kentucky.
Response
See Response to Applicant Interrogatory #24. f
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Interrogatory #25 State the utility company or individuals who supply water to each of the municipalities within the 50 mile Ingestion Pathway Emergency Planning Zone.
Response
See Response to Applicant Interrogatory #25. ? m
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Interrogatory #25a State whether or not standard operating procedures will be devised to insure the protection of public health and safety in the event of contamination of drinking water sources. If such standard operating procedures exist, attach a copy. Response - The Department of Natural Resources and Environmental Protection (DNREP) will use existing procedures for the sampling of contaminated drinking water sources. These procedures are available for review at the DNREP office in Frankfort, Kentucky. The Radiation Control Branch has draft
- Standard Operating Procedures for ingestion pathway sampling. These procedures are available for review at the Boone Natiorial Guard Center in Frankfort, Kentucky.
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1 1 ? Interrogatory #26 State whether or not the following plans are completed and if so attach a copy. If not, attach those parts of the following plans which have l been completed either in draft or final form and state the anticipated completion date for those parts not tirritten: a
- a. Northern Kentucky District Health Plan for a radiological emergency.
- b. a plan for the distribution and control of the tone alert i radio system.
j c. Any and all plans for coordination efforts between the j Commonwealth of Kentucky, Campbell, Bracken, and Pendleton j Counties, and the Zimmer Power Station public information officers. 4
Response
1 i a. This is available for inspection at the Northern Kentucky , Health District Office. i b. No plan exists. 4
- c. All plans for coordination efforts between the Commonwealth of Kentucky, Campbell, Bra cken, and Pendleton Counties, and the Zimmer Power Station public information officers are
- l. incorporated in their respective Radiological Emergency Plans.
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1 1 l l Interrogatory #27 State the number of the following items which the Commonwealth presently has:
- a. anti-contamination suits
- b. CDV-700 Survey meters with batteries and headphones
- c. gas maska
- d. signs reading: CAUTION RADIATION AREA
- e. Campbell County highway maps with monitoring locations marked t
- f. Bracken County maps with monitoring locations marked 4
- g. Pendleton County maps with monitoring locations marked
- h. lensatic compasses
- i. thermo-luminescent dosimeters i
- j. 'self reading pocket dosimeters.
4
Response
! a. 14 .
- b. 6,225
- c. 14 1 d. 8 (others~to be produced as needed).
e,f,g. 10 . h. none
- i. 400 1 j. Instrument Number l- .CDV-138 1,725 j CDV-730 1,700 CDV-740 910 CDV-742 25,746 l Other equipment of this type is maintained by the Kentucky State Police, the Kentucky National Guard, and the Bureau of Health Services.
Interrogatory #28 State the numbers of each of the items listed in interrogatory 27 which would be required to implement the Kentucky Emergency Radiological Plan for a general emergency. Response -
- These are indeterminate numbers; the number of each of these items used, if any, depends entirely on the circumstances of the emergency.
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l l Interrogatory #28a l List all county (Campbell, Bracken and Pendleton) and Kentucky State Officials who would be provided with pagers. Response . At the present time, the distribution list has not been finalize'd. A list of persons presently having pagers for emergency response are
, available for inspection at state and local DES organization offices.
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- l Interrogatory #28b
, List all drills and exercisen that have been staged in Kentucky to date.
1 1 Response i
- The following comprehensive radiological emergency response drills and
- exercises were conducted
October 29, 1981 Practice Exercise November 12, 1981 Practice Exercise
- November 18, 1981 FEMA /NRC Observed Exercise I In addition, many other drills were conducted by s ta te and local organizations for training purposes.
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Interrogatory #29 l During the November, 1981 exercises and/or drills held in Campbell l County were any standard operating procedures which are written, isolemented? If so, which ones?
Response
Yes. All the written standard operating procedures were used. i' l i e e l l l
1 1 l Interrogatory #30 List all organizations which participated in the drills referred to in interrogatory 29. Response ; The list of all organizations which participated in the . exercises is available at Campbell County Disaster and Emergency Services' office in Newport, Kentucky. O O 9
Interrogatory #30a State whether or not Federal Emergency Management Agency (FEMA) observers were present at the exercises and/or drills referred to in interrogatory 29. If so, attach a copy of any written observations made by FEMA observers.
Response
i Yes. A copy of written observations made by FEMA observers is ava'ilable at the Kentucky Disaster and Emergency Services' office in Frankfort, Kentucky. i I 4 d 4 l 4
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Interrogatory #31 State whether or not the Commonwealth and/or Campbell County had observers present at the Campbell County November, 1981 drills and/or exercises. If so, attach copies of any written observations made by those observers. !
Response
i Yes. Stone & Webster acting as observers for the Commonwealth of Kentucky and Kentucky DES personnel critiqued the emergency preparedness practice exercise on Nov. 12, and the Nov. 18, 1981 FEMA graded exercise. These comments may be examined at the Kentucky Disaster and Emergency
- Services headquarters in Frankfort, Kentucky.
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Interrogatory #32 If the Commonwealth or Campbell County had observers present at the
- Campbell County November, 1981 drills and/or exercises state what criteria they used in making evaluations of each exercise and/or drill.
Response
.i-The Nov 12, 1981 practice exercise and the Nov 18, 1981 FDfA graded exercise were evaluated with respect to the ability of participating organizations to respond as called for in the Campbell County Radiological Emergency Plan for the Wm. H. Zimmer Nuclear Power Station. l i j 4 e i l f' I J l 4 l
( Interrogatory #32a Which state agency shall have primary responsibility for providing observers for all future exercises or drills.
Response
Kentucky Disaster and Emergency Services has the primary responsibility. t e i l i t 4 i l 1 . f i i 1 I 1
I Interrogatory f33 Have any tests been conducted concerning the prompt notification system for Campbell County? If so, which part of the system has been tested, and how has it been tested?
Response
No tests of the proposed prompt notification system have been conducted. r e 1
( , . . Interrogatory #34 I Have any tests been conducted concerning the prompt notification system for Bracken County? If so, which part of the system has been tested, and hou was it tested?
Response
No tests of the proposed prompt notification system have been conducted. t t 4 e B e
Interrogatory #35 t Have any tests been conducted concerning the prompt notification rystem for Pendleton County? If so, which part of the system has been tested, and how was it tested? I 4
Response
No tests of the proposed prorpt notification system have been conducted. 1 f Y e 4 i e l 'b
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1 Interrogatorv #36 State the number of people who reside within five miles of the Zimmer Power Station in Campbell County. l 1 , Response t Information on the number 'M people in Campbell County who reside within five miles of the Zi ener Power Station is available in Appendix F-5 of the Cacrpbell County Ru ological Emergency Plan. 4 1 4 i I i i 1 't d 4 e e J i 0 Y d l I i i
4 Interrogatory #37 State the number of people who work, but do not live within five miles of the Zimmer Power Station in Campbell County? 4
Response
This information is not available i t e 4 .t x 4 4 f i a f 1 4 i 1 j J i b - i i 1 ) } 4 4 1 i
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l l Interrogatory #37a How r.any tone alert radios will be distributed to the residents of I Campbell County, and when will the distribution occur, and in what ! manner will it occur? !
Response
See response to Applicant Interrogatory #37a. 4 O 6 e
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1 l 1 i Interrogatory #38 State the number of people who reside within five miles of the Zimmer Power Station in Bracken County.
Response
Information on the number of people in Bracken County who reside
! within five miles of the Zimmer Power Station is available in Appendix F-5 of the Bracken County Radiological Emergency Plan.
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1 l l l Interrogatory #38a Interrogatory How many tone alert radios will be distributed tc the residents of Bracken County, when will the distribution occur, and how will it occur? t
Response
See response to Applicant Interrogatory #37a. t 9 4 e t ' e i
4 Interrogatory 439 l State the number of people who work, but do not live within five miles of the Zimmer Nuclear Power Station in Bracken County. 4
Response
This information is not available l l I, i t i 4 4 . 1 1 i i J . I i l 1 1 l i 1 5 1 l d J l 1 t
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Interrogatory #40 State the number. of people who reside within five miles of the Zimmer Nuclear Power Station in Pendleton County.
Response
Information on the number of people in Pendleton County who reside within five miles of the Zimmer Power Station is available in Appendix F-5 of the Pendleton County Radiological Emergency Plan. I t s e
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i Interrogatory #41 How many tone alert radios will be distributed to the residents of Pendleton County, when will the distribution occur, and how will it occur? l
Response
See response to Applicant Interrogatory #37a. 1 1 4 0 4 1 1, . ,I l I e i e i e a A 4 i l
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4 Interrogatory #42 State the number of. people in Canbell County who reside 'within five, , < miles of the , Zimmer ' Station but who are not within fifteen minutes of the Zinrner station by car. List and explain the set of.assuoptions used' , in order to arrive at this figure. Response 1. This information is not available i t S l l l l l
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Interrogatory #43
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. ,./ State -the number of people who work, but do not reside within five siles
./ ., ' of, -the ~ Zimmer Station and who are not within fifteen minutes of the
/ ' station by car while at work in Campbell County.
d[' 5 Resoonse
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This information is not available. i I h t i f 3 1 0 i f
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,Interroaatory #44 Provide the information called for by interrogatory 42 with respect to x Braeken Countv.
' Response This information is not available.
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l I Interroaatory d45 Provide the information called for by interrogatory 43 with respect to Bracken County.
Response
This information is not available.' I t e 1 i e
Interroaatory #46 Provide the information called for by interrogatory 42 with respect to Pendleton County.
Response
This information is not available. l t e O 4 4 e 4
i 1 Interrogatory #47 ! Provide the information called for by interrogatory 43 with respect to Pendleton County. ;
Response
This information is not available 0 e O 1 l _ _ ,, - - - - - ,. - ., , - - - -- --w -ee- r -
Interrogatory #48 State the number of people who reside within the plume exposure emergency planning zone in Kentucky.
Response
Information on the number of people in Kentucky who reside within the plume exposure emergency planning zone is available in Appendix F-5 of l the Campbell County Radiological Emergency Plan. 9 l l e
Interrogatory #49 State the number of people who work but do not reside within the plume exposure emerge cy planning zone in Kentucky. Response - This information is not available j I ie i j 1 a J 4 e 4 e
i Interrogatory #50 How many households are not within the range of a siren within five miles of the Zimmer Station in:
- a. Campbell County?
- b. Bracken County?-
- c. Pendleton County?
Response
f This information is not presently available 4 s e l l l I j i 1 1 l 1
'I 1 l 1 4 Interroaatory f51 1 How many deaf individuals live or work within five miles of the Zimmer .: Station in:
- a. Campbell County?
b. Bracken County?
- c. Pendleton County?
Response
This information is not presently available l . i l
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, Interrogatory #52 How many deaf individuals live or work within ten eiles of the Zimer . Station in:
- a. Campbell County?
- b. Bracken County? -
- c. Pendleton County?
Response
This information is ;ot presently available d I s l l 3 i j I i I I ! 'i l i 't l i I
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Interrogatory #53 4 How many blind peopic. live or work within five miles of the Zimmer Station in: 1 1
- a. Campbell County?
- b. Bracken County?
j c. Pendleton County? i j Response i
- This information is not presently available i
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l i Interrogatory #54 How many blind people live or work within ten miles of the Zimmer Station in:
- a. Campbell County?
- b. Bracken County?
- c. Pendleton County?
Response
This information is not presently available f 4 e [ i l 1 i 1 4 t i
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Interrogatory #55_ State what the power source is for each of the sirens to be used as part of the prompt notification system in Campbell, Bracken, .and Pendleton Counties. If an electrical power. source is to be used for any siren, state the name of the utility which will provide the electricity.
Response
See Response to Applicant Interrogatory #55. 4 s i i 4 4 1 l l l
l 1 Interrogatory #56 State whether or not any of the sirens referred to in interrogatory 55 will be equipped with an alternate power source, If so, identify the power source for each siren. Describe any maintenance plan to be used for each alternate power source.
Response
See Response to Applicant Interrogatory #56. l s I l t 1 4 4 i 3 l I l i {
Interrogatory #57 I State whether or not the in-home radios will be equipped with an alternate power source. If the answer is in the affirmative, state what the alternate power source will be. Describe any maintenance plan to be used for these alternate power sources.
Response
See Response to Applicant Interrogatory #57. i i J i l i i e d 1 l 1 l 1 e e 9 4 e sz
4 Interrogatorv #58 i What parts of Campbell County are serviced by Kentucky utilities? 4 2 Response See Response to Applicant Interrogatory #58. T 0 i-I 4 i i 1 3 1 1 4 1 i i ? i i a "4 i e
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j Interroaatory #59 What parts of Campbell County are serviced by Owen Rural Electric Co-operative? . Response i See Response to Applicant Interrogatory #59. e 4 4 1 1 I a } A l j - 1 { } 4 i 4 1 i j . o e e
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I Interroaatory #60 What parts of Campbell County are serviced by Unios Light Heat and Power?
Response
See Response to Applicant Interrogatory f60. a I 4 4 i l 5 t it i h 1 i
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Interrogatory #61 Inadvertantly deleted.
Response
N/A f l G 4
Interrogatory #62 i Tor the following utilities, state the dates, times of day or night and i
- duration of any electrical power outages experienced by residents of Campbell, Bracken and Pendleton Counties, respectively, who are within the 10 mile emergency planning zone, within the last year.
a) Union Light Heat and Power b) Owen Rural Electric Cooperative . c) Kentucky Utilities d) any additional utility listed in the answer to interrogatory number 56. 1
Response
t See Response to Applicant Interrogatory #62. i
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i Interroaatory #63 1 I State whether or not the Commonwealth has an alternate plan for prompt l aotification in the event that there is a power outage in one or more l , areas within the 10 mile emergency planning zone. If so, attach a copy. l
Response
j See Response to Applicant Interrogatory #63. l
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Interrogatorv #64 Identify the agency, company, entity or person who has (have) the primary responsibility for maintenance of the sirens.
Response
See Response to Applicant Interrogatory #64. 4 4 j 't k I 6 _________ _ _ __- g
Interrogatory #65 Identify the water source for each municipality within the 50 mile Ingestion Pathway emergency planning zone in Kentucky. Respcuse See Response to Ap;.licant Interrogatory #65. f O 4
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. . I Interrogatory #66 State whether or not plans have been formulated to isclate contaminated water from the water sources identified in the answer to Interrogatory number 65. If so, attach a copy.
Response
4 Plans for handling contaminated water are available for review a t. the Department of Natural Resources and Environmental Protection Office in Frankfort, Kentucky. 4 , J i t a d l . i 4 l 1 1 1
i Interrogatory #67 State whether or not plans have been formulated regarding the storage of contaminated water from the water sources identified in the answer to interrogatory number 65. If so, attach a copy.
Response
Plans for handling contaminated water are available for review at the Department of Natural Resources and Environmental Protection Office in P Frankfort, Kentucky.
Interrogatory #68 State whether or not plans have been formulated regarding the rationing of uncontaminated water for each of the counties within the 50 mile Ingestion Pathway Emergency Planning Zone in Kentucky. If so, attach a copy. l
Response
It is the perogative of the water district to decide what method of
, water rationing to institute. No formal plans exist.
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l l l 1 Interrogatory #69 State whether or not plans have been formulated regarding the transportation of uncontaminated drinking water. If so, attach a copy.
Response
No plans have been feraulated. Y b l 3 I 1 i I
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Interrogatory #70 i l State the number of mobile sirens which have been acquired by the for j use at Kincaid Lake Park. I j Response . I See Response to Applicant Interrogatory #70.
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Interrogatory #71 State the number of mobile sirens which have been acquired by the for
'use at A. J. Jolly Park.
, Response See Response to Applicant Interrogatory #71.
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Interrogatory #72 Identify the landing site for a helicopter in Falmouth, Kentucky 'to be used for the purposes for the landing of Federal Radiological Monitoring Agency Personnel. j'
' Response i
l The helicopter landing site is located at the i, tate highway gara'ge in 4 Falmouth, Kentucky. s i' i I' 9 ) . 2. 1
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l 1 Interrosatory #73 State whether or not the Cosumonwealth has plans to test the prompt notification systen under differing atmospheric conditions. If so, list the various atmospheric conditions the plan calls for.
Response
See Response to Applicant Interrogatory #73. 1 l I 4 I i f l O e f 1 2 I
l Interrogatory #74 List the number of training events by topic, that the Commonwealth has conducted to date and identify which personnel or organization were involved. Response - A. Emergency Response Table Top Training - 4
- 1. Kentucky Disaster and Emergency Services i
Operations Center personnel Department of Agriculture (Ky) Department for Human Resources
- State Fire Marshall
] Department of Energy (Ky) i Department for Human Resources - Food Branch
~
Department for Human Resources - Milk Control Department for Human Resources - Environmental i Department for Human Resources
- Sanitation Branch Ky Division of Telecommunications Ky Department of Education Kentucky National Guard i Red Cross CG&E representative 1 2. Bracken County Emergency Operations Center Police Chief (Augusta) and personnel Fire Department Chief (Brooksville)
~
Ambulance Service Police Dispatcher i DES Director, Bracken Sheriff
- Louisville / Jefferson County Civil Preparedness i
Mason County DES Coordinator
- KyDES Area Coordinators and planners '
] CG&E representative 4
)
- 3. Pendleton County Emergency Operations Center )
Fire Fighters Association personnel Mayor of Butler Judge / Executive Sheriff Deputy Sheriffs American Red Cross Cynthiana/ Harrison County DES Director School Superintendent Pendleton County Assessor KyDES Area Coordinators and planners CG&E representative. l l 1
l
- 4. Campbell Ccunty Emergency Operations Center
- Judge / Executive Kenton County
! Judge / Executive Grant County Commissioner Fiscal Court Administrator N.K.U. Public Safety Director Police Chief and personnel St. Luke Hospital radiologists TANK Transportation Manager Campbell Human Resources Director Northern Kentucky District Health Center Ft. Thomas DES Director County Extension Agent County DES Director KyDES Area Coordinators and planners Boone County DES Director Boone County Chief of Police DES Director, Kenton County DES Director, Grant County American Red Cross CG&E representative B. Notification and EOC Standard Operating Procedures Training -
4
- 1. Pendleton County Deputy Sheriffs Sheriff DES Director Ham Radio Operators Grant County DES Director KyDES Area coordinators and planners CG&E representative ,
- 2. Campbell County i DES Director .
CG&E representative ! 3. Campbell County i DES Director ! Police Chief j Deputy Police Chief CG&E representative i j 4. Bracken. County , Judge / Executive i Police Dispatcher 1 Sheriff l Extension Agent i Functional coordinators . l- DES Director KyDES Area Coordinators and planners l 2-i e
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C. Dose Assessment Training - 6 RCB Dose Assessment Team Members D. Decontaisination Center Training - 10 Volunteers E. Field Monitoring Training - 3 - } Department of Natural Resources personnel
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Interrogatorv #75 State the number of voice channel microwaves that have been installed in Kentucky and state their locations.
Response
See Response to Applicant Interrogatory #75. F l k i 'l I s i -i i } 1 t j - l 4 i I
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Interrogatory #76 State the number of tests which have been conducted of the communications equipment to be used in the event of a radiological emergency and state the dates that such tests were conducted. This question refers to communication equipment located in Kentucky.
Response
See Response to Applicant Interrogatory #76. i 4 , s ) 1 i d 'I 1 1 1 e 1 l 1
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Interrogatory #77 List the number of volunteers that the Kentucky Radiological Emergency Plan would require in order to implement every detail of that plan in the event of a general emergency and state the specific duties asked of each volunteer.
Response
The number of personnel needed to implement the Kentucky Radiological Emergeacy Plan varies according to the circumstances of the emergency. w 4 ) l, i T a i 4 -) i l 1 4 4
l Interrogatory #78 State whether or not the Commonwealth has a tape or transcript of any or all of the public meetings held regarding the Kentuc.ky, Campbell, 3' Bracken or Pendleton County Radiological Emergency Plans including the public meeting held in the evening in September of 1981 at the Alexandria Courthouse in Campbell County. If so, attach a copy of the 4 tape or transcript. Draft Response j A transcript of the Campbell County Public meeting is being prepared. Copies are not yet available. No transcripts or tapes are available from the Pendleton County Public Meeting. A tape is airailable of the s Bracken County Public Meeting } i
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Interrogatory #79 l State whether or not the Commonwealth has a tape or transcript of the ) public meeting held in New Richmond, Ohio on or about November 19, 1981 at 4:30 p.m at which Kentucky officials were present. If so, attach a copy. 1 l
Response
The Commonwealth of Kentucky has no. tape or transcript of the public j meeting. 9 9 D O O O
Interrogatory #80 i i List the items, materials and equipment that the Commonwealth of i Kentucky has requested from the Applicant in order to implement the l Kentucky Radiological Emergency Plan. l Response 1 j See Response to Applicant Interrogatory #80. A 2 ! t i . I J l 1 4 l 1 i ) 1 1
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. 1 i Interrogatory #81 l List the items, materials and equipment that the Comunonwealth of I Kentucky has obtained that are contained in the answer to interrogatory number 80.
i j Response 4 See Response to Applicant Interrogatory # 81. 4 . i 6 O k a l 1 i d f i a j l i I. 4 I 1 l - 1
Interrogatory #82 List the items, materials and equipment from the following list that the Commonwealth of Kentucky dces have. 4 a. a telemetry system capable of transmitting by means of radio signal the following data: a) wind direction: b) wind speed; c) differential temperature; d) Pasgill i stability class; e) primary containment high range - radiation level; f) primary ccntainment post accident radiation level; g) secondary containment radiation
; level; h) standby gas treatment stack radiation level;
., i) main plant vent stack radiation level; j) service
; water discharge radiation levels; k) fifteen station ring monitor radiation levels.
- b. microwave multiplex equipment and related telephone terminal.
1 s i Response l 0 See response to Applicant Interrogatory #82. ' l - I i l 1 i i I l 1J O 1 1 1 l l O I @ 0
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