ML20071K750

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First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence
ML20071K750
Person / Time
Site: Zimmer
Issue date: 07/29/1982
From: Conner T
CINCINNATI GAS & ELECTRIC CO., CONNER & WETTERHAHN
To:
CINCINNATI ALLIANCE FOR RESPONSIBLE ENERGY, GOVERNMENT ACCOUNTABILITY PROJECT, MIAMI VALLEY POWER PROJECT
References
NUDOCS 8208020204
Download: ML20071K750 (26)
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COCKETED U5!!RC UNITED STATES OF AMERICA h2 d 29 p4;36 NUCLEAR REGULATORY COMMISSION OFF:2 0F SECRETARv 00Ch;iP!Gr,s[Rv;j~ -

In the Matter of ) Bauw

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The Cincinnati Gas & Electric ) Docket No. 50-358

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(Wm. H. Zimmer Nuclear Power * "

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Station) )

APPLICANTS' FIRST SET OF INTERROGATORIES TO MIAMI VALLEY POWER PROJECT, CINCINNATI ALLIANCE FOR RESPONSIBLE ENERGY, AND GOVERNMENT ACCOUNTABILITY PROJECT, ET AL.

Pursuant to 10 C.F.R. S2.740b of the Nuclear Regulatory Commission's Rules of Practice, the Atomic Safety and Licensing Board's Memorandum and Order, dated Ju.ly 15, 1982, and Memorandum and Order (Memorializing Conference Call of July 21, 1982), dated July 21, 1982, The Cincinnati Gas &

Electric Company, et al., by their attorneys, hereby propound the following interrogatories relating to the Eight Additional Contentions, as defined below, to Miami Valley Power Project, Cincinnati Alliance for Responsible Energy, Citizens Against a Radioactive Environment, CARE, CAaRE, and 3 Government Accountability Project of the Institute for Policy Studies, any subsidiary, affiliate or parent of any of the foregoing, to be answered fully in writing under oath -

or affirmation and signed by the person (s) making them in accordance with the following definitions and instructions.

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PDR ADOCK 05000358 s

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Definitions and Instructions

1. For each interrogatory, please state the full name, address, occupation and employer of each person answering the interrogatory and designate the interrogatory or part thereof which he or she answered.
2. The following definitions shall apply:

(a) " Respondent" shall mean Miami Valley Power Project, Cincinnati Alliance. for Responsible Energy, Citizens Against a Radioactive Environment, CARE, CAaRE, and Government Accountability Project of the Institute for Policy Studies, any subsidiary, affiliate or parent of any of the foregoing, or any officer, agent, director, member, or attorney thereof, as appropriate.

(b) " Person" shall mean an individual, person, corporation, proprietorship, partnership, or any other entity.

(c) " Identification" or " identify" when referring to an individual, corporation or other entity shall mean that intervenor shall state the name and present or last known address. As to a corporation or other entity, intervenor shall also state its principal place of business and, as to an individual, his or her title or titles, employer, and employer's address. Once an individual, corporation or other entity has been l

_ _ _ - _ _ _ _ _ i

thus identified in answer to an interrogatory, it_ l shall- be sufficient thereafter when identifying that individual, corporation, or other entity to state merely his,-her or its name.

(d) " Description" or " describe" when referring to a document as hereinafter defined shall mean that the respondent shall set forth the author or originator, addressee (s), date, title and subject matter, the present custodian of any copy thereof and the last known address of each such custodian if such information is not already provided in the document itself. In lieu of describing a document, respondent may submit a copy thereof to undersigned counsel within the time prescribed by 10 C.F.R. S2.740b, indicating the request to which the attached document responds.

(e) " Document" shall mean any written, printed, typed or any other graphic matter.of any kind or nature, however produced or reproduced, including but not limited to the original or any copy of books, records, reports, correspondence, memoranda, notes, written communications, telegrams and cables, notes of oral or telephonic communications, diaries, schedules, calendars, graphs, charts, contracts, agreements, releases, f appraisals, valuations, estimates, projections, work papers, opinions, studies, analyses,

summaries, booklets, circulars, bulletins, instructions, minutes or notes of meetings, resolutions, photographs, tabulations, questionnaires, tapes, surveys, messages, tables, drawings, sketches, financial statements, as well as any other tangible things on which information is recorded in writing, by sound, magnetically, or in any other manner and including supporting, underlying or preparatory material, in the possession, custody or control of respondent or its officers, members, employees, agents or consultants and, unless privileged, its attorneys.

It shall also mean all copies or drafts of documents by whatsoever means made. Each copy of the same document or draft of a document shall constitute a separate document to be produced if there are any differences in notations, handwritten comments or other markings thereupon.

(f) "Date" shall mean exact day, month and year, if ascertainable, or, if not ascertainable, the best approximation (including the relationship to other events);

(g) "Zimmer Station" shall mean the Wm. H. Zimmer Nuclear Power Station, located in Clermont County, Ohio and all appurtenant facilities; (h) "CG&E" shall mean The Cincinnati Gas & Electric Company; I

(i) "KEI" shall mean Kaiser Engineering, Inc.

(j) " Employee" shall mean any present or .former employee of CG&E, its principal constructor, contractors, subcontractors, consultants and vendors furnishing any system, component or part or rendering any services for the construction, quality assurance and licensing of the Wm. H.

Zimmer Nuclear Power Station. It also shall include an individual who by contract is providing services equivalent to an employee as defined above.

(k) "QA" shall mean quality assurance.

(1) "QC" shall mean quality control.

3. If respondent claims that any document or other information requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addressee; (d) present location and custodian; I

l (e) any other description necessary to enable the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to

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!s protect the privilege or confidential nature of any such document;

4. If respondent claims any information not in documentary form is privileged, the nature of such privileged information as well as the information requested by items 3 (f) and (g) shall be provided.
5. If a request is made for information relating to a specific condition, deficiency, defect or inadequacy in any system, component, or structure of the Zimmer Station, the following information should be supplied in each instance:

(a) the structure, system or component involved and its exact location with as much specificity as possible; (b) the exact nature of the condition, defect, deficiency or inadequacy alleged; (c) the individual who identified the condition, deficiency, defect or inadequacy; ,

(d) the date or period in which the condition, defect, deficiency or inade6uacy was discovered; (e) any corrective or mitigative actions taken; '

(f) why such corrective or mitigative actions were inadequate; (g) the specific manner in which such conditicn, defect, deficiency or inadequacy was brought to the attention of respondents, including the specific individuals and dates involved.

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6. In the context herein, "Eight Additional ' Contentions" p\ refer to the eight contentions admitted by the Atomic TL a c Safety and Licensing Board by its Memorandum'and Order (July 15, 1982) as set forth in the 17-page attachme t thereto. 3 x 7. 'These interrogatories request all knowledge or d

information in respondents' possession and/or knowledge and.. 'information in the possession of respondents' officers, directors, members, agents and consultants, and, unless privileged, attorneys. .

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Interrogatories Contention 1 , s

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1. Describe fully each and eve stance in rhich the

.as-built condition of the Zimmer Station.'does, not

~. s s comply with all applicable regulations and requirements for public health and safety.

2. Describe each instance in which installation of a.

s structure, system, or component of the Zimmer Station has proceeNed cn the basis of construction al'ds rather than approved final drawings.

3. Describe each-instance in which design revisions have not been fully incorporated and distributed to all

, relevant construction and QA personnel.

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4. Describe each instance in which the Quality Assurance Program and implementing procedures of The Cincinnati Gas & _ Electric Company, its architect engineer, its constructor or other constructors and subcontractors I i

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p. have failed to. meet the requiremergts of 10 C.F.R. Part

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50 / Appendix B.

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5. Describe every instan e~for which specirIdd equipment a

was not installed in the designated location.

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6. Describo/cach instancewhfre ""

Sargent & Lundy approved

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, t - erroneods' Design;Documer3t Changes, idantifying each by 1

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,, ip,unber; or other specific designation and describing the J ~

c l' specified elrror./j311e.ged

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7. Identify each

' person who prdvided, his agreed to

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provide or with' whom respondent ha's , discussed, an

) > . ll l J r affidavit concerning this , concention, '.3ummarizing the

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. substance of the~ affidavit.

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8. . Identify each employee. whci will testify or whom respondents have contacted'concerning this contention.

State their qualifications to te'stify and summarize the substance 5f their testimony in addition to providing the information requested by Interrogatory 87.

9. Describe the internal CG&E and KEI documents which form a part of the basis for this contention.

Contention 2

10. Identify and describe each instance in which CG&E or KEI has failed to maintain adequate traceability of materials, to identify and document the history of any material, parts, components or welds.
11. Identify all inaccurate or overgeneralized blueprints, lack of identifying markings on equipment, installation

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damage to materials and missing, incomplete or tnreliable records which form a basis for this contention.

12. Describe each instance for which " guessing and unproven assumptions" affect existing traceability records.
13. Identify each person who provided, has agreed to provide or with whom respondent has discussed, an affidavit concerning this contention, summarizing the substance of the affidavit.
14. Identify each employee who will testify or whom respondents have contacted concerning this contention.

State their qualifications.to testify and summarize the substance of their testimony in addition to providing the information requested by Interrogatory 87.

15. Describe the internal CG&E and KEI documents which form a part of the basis for this centention.

Contention 3

16. Identify and describe each instance in which the quality assurance program for vendor purchases at Zimmer fails to meet the requirements of 10 C.F.R. Part 50 Appendix B, Criterion VII.
17. State the basis for the assertion that " [ t] he QA breakdown for vendor purchases has been systematic . . . .
18. Specify and describe each and every instance where vendors have been accepted for the Approved Vendors List (" AVL") "on the most superficial basis."

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19. Identify and describe all instances of " toleration of hardware defects uncovered after instalJ.ation."
20. Identify and describe each and every " unqualified vendor" that has been placed on the AVL and describe each and every instance of " poor performance" by such

" unqualified" vendors, identifying with particularity the structure, system, components or parts involved and the exact nature of the defect (s) in or poor quality of the work performed or supplied by such " unqualified" vendors.

21. Identify and describe the basis for the assertion that "once on the AVL list,. it has been unreasonably difficult to remove the vendors despite poor performance," describing in detail each instance of poor performance.
22. Identify and describe each and every instance which CG&E has " improperly" made vendor purchases and then directed KEI to assume quality assurance responsibility for the purchases.
23. Identify each and every instance in which KEI receipt inspection of vendor purchases was improperly restricted and describe as to each the inspection procedure (s) improperly omitted.
24. Identify and describe each and every instance for which CG&E denied permission to KEI to conduct necessary source inspections of vendors.
25. Identify each and every instance for which CG&E or KEI did not maintain reliable, comprehensive identification records and documentation packages which resulted in uncertain traceability of materials.
26. Identify and describe each component or part which is alleged to have been improperly upgraded from "non-essential" to " essential."
27. Identify and describe each and every instance where QA/QC inspectors found defects in vendor hardware but were instructed not to write up Nonconformance Reports.
28. State the complete basis for the assertion that vendor purchases at Zimmer are not covered by onsite QA inspections.
29. Identify and describe each and every instance where items fabricated onsite have been " erroneously defined

- out of the CG&E and KEI QA systems."

30. Identify each person who provided, has agreed to provide or with whom respondent has discussed, an affidavit concerning this contention, summarizing the substance of the affidavit.
31. Identify each employee who will testify or whom respondents have contacted concerning this contention.

State their qualifications to testify and summarize the substance of their testimony in addition to providing the information requested by Interrogatory 87.

32. Describe the internal CG&E and KEI documents which form a part of the basis for this contention.

Contention 4

33. Identify and describe each instance in which construction deficiencies have been identified and not corrected.
34. Specify the NRC regulation (s) or other source requiring a single comprehensive quality assurance manual for CG&E and KEI QA/QC personnel.
35. Provide the basis for the allegation that training procedures for QA/QC personnel have been inadequate, specifying each procedure, training session and individuals involved.
36. Provide the basis for the. allegation and describe all instances in which training classes for QA/QC personnel were taught by unquclified instructors.
37. Describe each and every instance for which mandatory inspections did not occur for safety-related items.
38. Describe each and every instance where necessary audits were not conducted for " unjustifiable [ sic] long periods," defining this phrase as utilized in this contention.
39. Describe each and every instance in which CG&E and KEI management have not made " good faith" efforts to comply with audit recommendations.
40. Identify and describe each and every instance where corrective action procedures for identified construction defects have failed to consider

reinspection for damage that may have previously been overlooked.

41. Describe each and every instance for which a lack of independence for QA/QC departments and personnel for construction counterparts in both CG&E and KEI organizations has contributed to "[t]he absence of even a minimally acceptable QA program."
42. Identify each person who provided, has agreed to provide or with whom respondent has discussed, an affidavit concerning this contention, summarizing the substance of the affidavit.
43. Identify each employee .who will testify or whom respondents have contacted concerning this contention.

State their qualifications to testify and summarize the substance of their testimony in addition to providing the information requested by Interrogatory 87.

44. Describe the internal CG&E and KEI documents which form a part of the basis for this contention.

Contention 5

45. Identify and describe each and every instance for which CG&E or KEI officials failed to maintain adequate controls to process and respond to internal Nonconformance Reports, identifying the specific violation of internal or governmental requirements.
46. Describe the basis for the assertion that potentially thousands of Nonconformance Reports have been improperly voided or discarded under the QA program.

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47. Describe in detail the " convoluted system of multiple approvals which makes it unreasonably difficult to issue NRs."
48. State the basis for the assertion that CG&E's present system of reporting nonconforming conditions is not of the type commonly used at other nuclear power facilities.
49. State the basis for the statement that the QA report categories utilized at Zimmer violate 10 C.F.R. Part 50, Appendix B, specifying the criterion or criteria violated and the manner in which such criteria have been violated.
50. Identify and describe et-ch known instance of " dormant, identified deficienciec" wn.tch were found and later lost or dispositioned without correcting the identified defects.
51. Identify and describe each and every instance where CG&E and KEI have engaged in " illegal retaliation" against QA/QC personnel.
52. Identify each person who provided, has agreed to provide or with whom respondent has discussed, an affidavit concerning this contention, summarizing the substance of the affidavit.
53. Identify each employee who will testify or whom respondents have contacted concerning this contention.

State their qualifications to testify and summarize the

substance of their testimony in addition to providing the information requested by Interrogatory 87.

54. Describe the ir.iernal CG&E and KEI documents which form a part of the basis for this contention.

Contention 6

55. Identify and describe each and every instance for which CG&E and KEI " openly tried to discourage or neutralize QA/QC initiatives, internal disclosures or employee disclosures to the NRC," describing the QA/QC employees who were prevented from perlorming their duties, the persons who were responsible for such alleged action or retaliation, the persons who carried out the retaliatory actions, the dates and nature of such acts, and the manner that such information became known to respondents.
56. Identify and describe any known or suspected construction personnel who have physically or verbally intimidated QA or QC inspectors or personnel, stating the manner in which such information became known to respondents, the QA/QC employees who were intimidated, the persons who were responsible for such intimidation, the dates and nature of such intimidation, and the manner that such information became known to respondents.
57. Describe and present fully the basis for the assertion that management officials did not pursue and discipline the harassment offenders or take steps to deter l

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repeated harassment, specifying the individuals involved, the dates or periods during which such harassment occurred and the manner that this information became known to respondents.

58. Identify and describe each instance for which "KEI top management berated QC inspectors and supervisors for writing up nonconformances," identifying the individuals involved, describing all other details of such incidents, and the manner that this information became known to respondents.
59. Describe and identify each instance for which CG&E or KEI management retaliated against employees who pursued corrective action programs for QA violations or disclosed QA violations to the NRC, identifying all individuals involved and describing the alleged reprisals, all other details of the alleged incidents, and the manner that this information became known to respondents.
60. Identify with specificity those employees who were interviewed by CG&E counsel and "who retracted or modified their statements made to the NRC" in order to keep their supervisory positions, identifying the CG&E counsel involved and the dates of such interviews, and describing all other details of each incident and the manner that this information became known to respondents.
61. Identify and describe the basis for the assertion that CG&E removed Butler Services, Inc. and Peabody Magnaflux, Inc. from responsibilities for QC and radiographs, respectively, "in an effort to destroy the independence of this portion of the QA program."
62. Identify each instance and describe the basis for the assertion that " reprisal victims were replaced with substitutes whose qualifications and commitments to cound QA practices are open to serious challenge."
63. Identify each person who provided, has agreed to provide or with whom respondent has discussed, an affidavit concerning this. contention, summarizing the substance of the affidavit.
64. Identify each employee who will testify or whom respondents have contacted concerning this contention.

State their qualifications to testify and summarize the substance of their testimony in addition to providing the information requested by Interrogatory 87.

65. Describe any additional documents which form a part of the basis for this contention.

Contention 7

66. Provide the complete basis for the assertion that the CG&E Quality Confirmation Program is inadequate to mitigate or remedy the serious consequences of QA breakdown at the Zimmer Station, stating in each aspect for which the QCP is alleged to be fundamentally deficient in its scope or implementation.

, 67. Provide the basis for the assertion that CG&E alone has the discretion to select small samples for reinspections.

68. State your understanding as to NRC review or approval of the sample selection for reinspection.
69. Provide all "new information obtained by MVPP" which evidences potential QA and hardware problems " ranging far beyond those disclosed in the IE report" and which

" demonstrates the need for a hundred percent reinspection of all safety equipment installed on site."

70. State all conversations with I&E Region III management officials which provide a basis for this contention, identifying the official and the date of each conversation and describing its substance.
71. Identify each person who provided, has agreed to provide or with whom respondent has discussed, an affidavit concerning this contention, summarizing the substance of the affidavit.
72. Identify each employee who will testify or whom respondents have contacted concerning this contention.

State their qualifications to testify and summarize the substance of their testimony in addition to providing the information requested by Interrogatory 87.

73. Describe the internal CG&E and KEI documents which form a part of the basis for this contention.

Contention 8

74. Provide the full basis for the assertion that CG&E lacks the necessary character and competence to operate a nuclear power plant.
75. State the full basis for the assertion that "CG&E management has made key decisions about the QA program and has had a dominant role since at least 1974."
76. State the full basis for the assertion that "CG&E . . .

denied Kaiser authorization to spend funds for adequate QA staff and training . . . .

77. State the full basis for the assertion that the "CG&E construction department generally dominated the applicants' QA program."
78. Identify and describe each and every instance in which false statements are alleged to have been made to the NRC by or on behalf of CG&E, identifying the individuals involved, the exact statements made, the dates when such statements were made, and specify whether such " false statements" were intentional or otherwise, and the date and manner that this information became known to respondents.
79. State the full basis for the assertion that records relating to QA defects were " intentionally falsified."
80. State and discuss each and every instance in which construction crews made " informal, undocumented repairs on welds."
81. Provide the basis for the allegation that "KEI employees have engaged in deceptive conduct towards the NRC," stating in each case the deceptive conduct, dates involved, identifying the individuals involved.
82. State the basis for the assertion that ongoing criminal investigation is directed towards CG&E.
83. State the basis for the assertion that any CG&E official is the subject of any criminal investigation.

General

84. If your answers to Interrogatories 1 through 83 above, in whole or in part, are based upon documents, provide the following information:
a. describe each such document on which your answer is based;
b. identify the information in each document on which your answer is based;
c. explain how such information provides a basis for your answer.
85. If your answers to Interrogatories 1 through 83 above, in whole or in part, are based upon any type of study, calculation or analysis, provide the following information:
a. describe the nature of the study, calculation, or analysis and identify any documents which discuss or describe the study, calculation or analysis;
b. identify the person (s) who performed the study, calculation or analysis;
c. state when and where the study, calculation or analysis was performed;
d. describe in detail the information that was studied, calculated or analyzed;
e. describe in detail the results of such study, calculation or analysis;
f. explain how such study, calculation or analysis provides a basis for your answer to each respective interrogatory on which it is based.
86. If your answers to Interrogatories 1 through 83 above, in whole or in part, are based upon research, provide the following information: ,
a. describe all such r'esearch and identify each document discussing or describing such research;
b. identify the person (s) who conducted the research;
c. state when and where the research was conducted;
d. explain how such research provides a basis for your answer to each respective interrogatory on which it is based.
87. If your answers to Interrogatories 1 through 83 above, in whole or in part, are based upon conversations, consultations, correspondence or any other type of communications with one or more individuals, provide the following information:
a. identify each such individual;
b. state the educational and professional background of each such individual, including occupational and

institational affiliations. Please attach a copy of the most recent statement of professional qualifications;

c. describe the nature of each communication with each such individual, when it occurred, and identify all other individuals involved;
d. describe the information received from each such individual and explain how it provides a basis for your answer to each respective interrogatory on which it is based;
e. if such individual is an employee, identify the employer and state the, dates of employment and his responsibilities relating to the design, construction, quality assurance or operation of the Zimmer Station.
88. Identify which of the documents described in response to these interrogatories respondent will seek to introduce into evidence.
89. Describe any other documents not previously included in respondents' answers above which will be used during cross-examination of the Applicants' and NRC Staff's witnesses.
90. Identify all individuals having expertise regarding respondents' contentions whom intervenor has contacted or intends to contact, directly or indirectly, or who has contacted respondents, directly or indirectly, regarding such contentions and provide a summary of any

information and/or opinion given by such individual

, with regard to the contentions, whether or not such l

l information supports the contention.

91. For each of the individuals identified in response to Interrogatory 90, state his home address, telephone l number, present employer and address, present occupation and title or position, and his education and training which give him expertise with regard to the contentions. Identify all sections of the Zimmer Station application, applications pending before other agencies or other documents related to the Zimmer Station, studied or read by each individual with regard to respondents' contentions.
92. Identify all individuals which respondents intend to utilize on its behalf in the examination and cross-examination of expert witnesses pursuant to 10 C.F.R. S2.733, giving the information requested by Interrogatory 91 and setting forth any additional information which may tend to show that the individual has scientific or technical training or experience to so participate.
93. Please state when the Government Accountability Project of the Institute for Policy Studies (" GAP") became the attorney for any of the respondents, specifying which of respondents is the client and which individual attorneys, who are employed by or associated with GAP,

. are attorneys for such respondent or whether the organization, as such, is serving in that capacity.

CONNER & WETTERHAHN

, 7 Troy B. onner, Jr.

Counsel for the Applicants 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 2006 (202)833-3500 s July 29, 1982

d flV W UNITED STATES OF AMERICA ..,,

NUCLEAR REGULATORY COMMISSION 7". " bn g , 6 42 ,

In the Matter of ) 0Ff!?? CF SECRthP

) uGCCTa'G & CERVICE Docket No. 50-358 BRANCH The Cincinnati Gas & Electric )

Company, et al. )

)

(Wm. H. Zimmer Nuclear Power )

Station) ) s ,

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' First Set of Interrogatories to Miami Valley Power Project, Cincinnati Alliance for Responsible Energy, and Government Accountability Project, et al." dated July 29, 1982 in the captioned matter, have been served upon the following by deposit in the United States mail or by hand delivery as indicated below this 29th day of July, 1982:

Alan S. Rosenthal, Chairman Dr. Frank F. Hooper Atomic Safety and Licensing Sierra Nevada Aquatic Appeal Board Research Laboratory U.S. Nuclear Regulatory Route 1 Commission Box 198 Washington, D.C. 20555 Mammcth Lakes, CA 93546 Stephen F. Eilperin Dr. M. Stanley Livingston Atomic Safety and Administrative Judge Licensing Appeal Board 1005 Calle Largo U.S. Nuclear Regulatory Sante Fe, NM 87501 Commission Washington, D.C. 20555 Chairman, Atomic Safety and Licensing Appeal Howard A. Wilber Board Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Appeal Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Chairman, Atomic Safety and Licensing Board Judge John H. Frye, III Panel Chairman, Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

, Charles A. Barth, Esq. David K. Martin, Esq.

Counsel for the NRC Staff Assistant Attorney General Office of the Executive Acting Director Legal Director Division of U.S. Nuclear Regulatory Environmental Law Commission Office of Attorney General Washington, D.C. 20555 209 St. Clair Street Frankfort, Kentucky 40601 Deborah Faber Webb, Esq.

7967 Alexandria Pike George E. Pattison, Esq.

Alexandria, Kentucky 41001 Prosecuting Attorney of Clermont County, Ohio Andrew B. Dennison, Esq. 462 Main Street Attorney at Law Batavia, Ohio 45103 200 Main Street Batavia, Ohio 45103 William J. Moran, Esq.

Vice President and Lynne Bernabei, Esq. General Counsel Government Accountability The Cincinnati Gas &

Project /IPS Electric Company 1901 Q Street, N.W. P.O. Box 960 Washington, D.C. 20009 Cincinnati, Ohio 45201 John D. Woliver, Esq. .

Docketing and Service Clermont County Branch Office of the Community Council Secretary U.S. Nuclear Box 181 Regulatory Batavia, Ohio 45103 Commission Washington, D.C. 20555 Brian Cassidy, Esq.

Regional Counsel Federal Emergency Management Agency Region I John W. McCormick POCH Boston, MA 02109

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Ma{k/ J . Wetterhahn cc: Robert F. Warnick Director, Enforcement and Investigation NRC Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 nd Delivery

____________ _

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