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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20071K7501982-07-29029 July 1982 First Set of Interrogatories.Certificate of Svc Encl. Related Correspondence ML20058B7661982-07-23023 July 1982 First Request for Production of Documents.Certificate of Svc Encl ML20054K6271982-06-0707 June 1982 Interrogatory Re How Zirconium Oxide & Water Bound Electrolytes Catalyze Formation of Hydrogen from Water at Sufficiently High Temps ML20039E9611982-01-0505 January 1982 Objection to City of Mentor,Ky 811215 Formal Discovery Requests.Absurd to Request Formal Admissions from Nonparty. Informally,Interrogatories Have Been Answered. Certificate of Svc Encl.Related Correspondence ML20039E5881982-01-0404 January 1982 Responses to City of Mentor 811214 Interrogatories. Certificate of Svc Encl.Related Correspondence ML20039E9501981-12-31031 December 1981 Response to Requests for Admissions.Certificate of Svc Encl. Related Correspondence ML20039D7351981-12-30030 December 1981 Response to Zimmer Area Citizens-Zimmer Area Citizens of Ky 811215 Request for Admissions ML20039D7311981-12-30030 December 1981 Objections to Certain Zimmer Area Citizens-Zimmer Area Citizens of Ky 811215 Requests for Admissions.Certificate of Svc Encl ML20039E5791981-12-29029 December 1981 Response to City of Mentor Requests for Admissions.Related Correspondence ML20039D7371981-12-29029 December 1981 Response to City of Mentor 811214 Requests for Admissions. Certificate of Svc Encl ML20039C1841981-12-28028 December 1981 Objections to Formal Discovery Requests of ZAC-ZACK. Commonwealth of Ky Does Not Have Any Contentions in Proceeding,Thus Is Not Party.Certificate of Svc Encl ML20039C1881981-12-23023 December 1981 Objections to Listed 811204 Interrogatories.Discovery May Not Compel Party to Generate New Info.Each Party Has Responsibility to Do Own Pretrial Work.Protective Order Should Be Issued ML20039C1831981-12-23023 December 1981 Responses to ZAC-ZACK 811204 Interrogatories.Certificate of Svc Encl ML20039C1851981-12-22022 December 1981 Response to ZAC-ZACK Interrogatories.Certificate of Svc Encl ML20039B5671981-12-21021 December 1981 Requests for Admissions by Commonwealth of Ky ML20039B5291981-12-21021 December 1981 Requests for Admissions Directed to Applicant ML20039B5231981-12-21021 December 1981 Requests for Admissions Directed to Clermont County,Oh ML20039B1071981-12-14014 December 1981 Request for Admissions.Related Correspondence ML20039B1031981-12-14014 December 1981 Request for Admissions.Related Correspondence ML20039B0421981-12-14014 December 1981 Interrogatories Directed to Commonwealth of Ky.Related Correspondence ML20039B0301981-12-14014 December 1981 Interrogatories Directed to Applicant.Related Correspondence ML20038B9741981-12-0404 December 1981 Objections to Fankhauser 811125 Interrogatories 3 Through 11 & Response to Interrogatories 1,2 & 12.Certificate of Svc Encl.Related Correspondence ML20038B9721981-12-0404 December 1981 Responses to Fankhauser Interrogatories.Related Correspondence ML20039A1901981-12-0404 December 1981 Interrogatories Directed Towards Applicant.Certificate of Svc Encl ML19341A7951981-01-23023 January 1981 Response to NRC Second Second Set of Interrogatories Re S&W Evacuation Time Study.Prof Qualifications & Certificate of Svc Encl ML20003A1391981-01-20020 January 1981 Answers of Miami Valley Power Project to Applicant Seventh Set of Interrogatories Re Witnesses & Decommissioning Costs. Analysis of Decommissioning & Premature Shutdown Costs of Plants & Certification of Svc Encl.Related Correspondence ML19339B0221980-10-28028 October 1980 Response to NRC 801010 Interrogatories Re S&W Study on Population Evacuation.Study Is Subj to Revision Due to Development of NRC Position & State & Local Emergency Plans. W/Certificate of Svc.Related Correspondence ML19262A9791979-11-27027 November 1979 Response to Intervenor Miami Valley Power Project Interrogatories Re Contention 13,concerning Delay in Fuel Loading Date.Certificate of Svc Encl ML19262A9641979-11-21021 November 1979 Seventh Set of Interrogatories Re Intervenor Contention 13. Certificate of Svc Encl ML19253C7101979-11-0808 November 1979 Interrogatories Re Contention 13.Certificate of Svc Encl ML19209B2111979-09-11011 September 1979 Responses to Miami Valley Power Project Interrogatories Re Contention 17.Contains Affirmation That Test at Const Technology Labs Was Designed to Qualify Fire Barrier Capability of Kaowool Matl Only.Certificate of Svc Encl ML19209B1531979-08-24024 August 1979 First Set of Interrogatories Directed to Nrc.Includes Questions Re Fires Occurring within Cable Trays, Identification of Plants Where Such Occurrences Took Place & Procedures Applied to Prevent Similar Fires ML19209B1581979-08-24024 August 1979 Interrogatories Directed to Applicant Re Contention 17. Includes Questions Re Layers & Thickness of Kaowool Covering Cable Trays,Heat Generated by Cables,Tests Performed on Fire Safety & Other Related Matters.W/Certificate of Svc ML19249D5441979-08-24024 August 1979 Sixth Set of Interrogatories to Intervenor Miami Valley Project.Certificate of Svc Encl ML19225A6041979-06-15015 June 1979 Cincinnati Gas & Electric Further Responses to Miami Valley Power Project Third Set of Interrogatories.Affidavit & Certificate of Svc Encl ML19256B4451979-05-30030 May 1979 Miami Valley Power Project Answers to Certain of NRC Interrogatories.Affidavit & Certificate of Svc Encl ML19269E4281979-05-14014 May 1979 Applicant Responses to Intervenor Miami Valley Power Project Third Set of Interrogatories.Affidavit & Certificate of Svc Encl ML19241A9441979-05-0909 May 1979 Intervenor Miami Valley Power Project Answers to NRC 790420 Interrogatories ML19241A9571979-05-0909 May 1979 Intervenor Miami Valley Power Project Answer to Cincinnati Gas & Electric 790420 Fifth Set of Interrogatories ML19289F0291979-03-19019 March 1979 Second Set of Interrogatories Submitted to Applicant. Certificate of Svc Encl ML19289E9231979-03-13013 March 1979 Submits Supplementary Answers to Applicant'S Second Set of Interrogatories.Affidavit Encl ML19289E8541979-03-0808 March 1979 Serves Fourth Set of Interrogatories on Miami Valley Power Project.Certificate of Svc Encl ML19273B4851979-03-0202 March 1979 Intervenor Miami Valley Power Project'S First Set of Interrogatories to Applicant.Queries Concern Reed Rept,Const Costs,Decommissioning Expenditures & Projected Capacity Factor.Certificate of Svc Encl ML19261A2791978-12-19019 December 1978 Applicant'S Second Set of Interrogatories Propounded to Intervenor Miami Valley Power Project Pertaining to Contentions as Admitted as Issues by ASLB 760319 Order. Certificate of Svc Encl 1982-07-29
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20056E5101993-08-11011 August 1993 Comment Opposing Proposed Rule 10CFR20 Re Radiological Criteria for Decommissioning ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal IR 05000358/19820101986-06-24024 June 1986 Applicant Exhibit A-49,consisting of Forwarding Partially Withheld Safety Insp Rept 50-358/82-10 on 820607- 0818 (Ref 10CFR2.790) & Notice of Violation ML20129A3751985-05-16016 May 1985 Order Revoking CPPR-88,based on Util 840127 Plan to Convert Facility to Coal Fuel ML20133N3621985-03-14014 March 1985 Unexecuted Amend 3 Terminating Indemnity Agreement B-85 ML20094C3571984-08-0202 August 1984 Transmittal of Info Re Util 840320 Motion for Withdrawal of OL Application.Fuel Removed from Site,Steam Supply Sys Modified & CRD Mechanisms Removed.Certificate of Svc Encl ML20087H7881984-03-20020 March 1984 Motion Requesting Issuance of Order Authorizing Withdrawal of Application.Plant Will Be Used as Part of New Fossil fuel-fired Electric Generating Plant.Certificate of Svc Encl ML20087N2281984-03-0101 March 1984 Endorsement 25 to Nelia Policy NF-249 ML20079F8181984-01-16016 January 1984 Response Opposing Miami Valley Power Project 831231 Proposed Issues & Support for Contentions Re Qa.Issues Not Specific or Litigable.Certificate of Svc Encl ML20083J5321983-12-31031 December 1983 Proposed Issues & Prospective Witnesses Supporting Miami Valley Power Project Proposed Contentions Re Qa,Character & Competence.Certificate of Svc Encl ML20079H6901983-12-14014 December 1983 Petition Per 10CFR2.206 to Defer Judgment or Decision on Proposed Course of Action for Completion of Facility Until Suppl Created for Record of J Keppler 831215 Briefing.W/O Encls ML20082P8501983-12-0606 December 1983 Response Opposing City of Mentor 831115 Memorandum in Support of NRC 831031 Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen Record.Motion W/O Merit.Certificate of Svc Encl.Related Correspondence ML20082M5791983-12-0202 December 1983 Response Opposing Applicant 831115 Answer to NRC 831031 Motion to Defer Ruling on Petition for Reconsideration & Motion for Leave to File Addl Evidence Prior to 831215 Conference of Counsel.Certificate of Svc Encl ML20082L0991983-11-30030 November 1983 Memorandum in Support of City of Mentor Motion to Further Defer Rulings Until Completion of Investigation Into Matl False Statements by NRC & Applicants.Certificate of Svc Encl ML20082D6991983-11-15015 November 1983 Memorandum in Support of NRC Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen & City of Mentor Motion to Further Defer Rulings Until Completion of Investigation.Certificate of Svc Encl ML20081M7951983-11-15015 November 1983 Answer Opposing NRC Motion to Defer Rulings on Miami Valley Power Project (MVPP) 831003 Motion to Reopen Record.Decision Should Not Be Deferred to Await Completion of Investigation. Certificate of Svc Encl ML20085K7841983-10-18018 October 1983 Answer Opposing Miami Valley Power Project 831003 Petition for Reconsideration of ASLB 830915 Memorandum & Order Denying Project Motion to Reopen Record to Admit Eight Late Filed Contentions on Qa.Certificate of Svc Encl ML20078K5621983-10-13013 October 1983 Memorandum in Support of Miami Valley Power Project (MVPP) Petition for Reconsideration of ASLB 830915 Order.Mvpp Urges ASLB to Address Stds for Reopening Record.Issues Should Be Included to Ensure Complete Record.Certificate of Svc Encl ML20078F9641983-10-0606 October 1983 Notification to Commission of Miami Valley Power Project Misrepresentation in 831003 Motion for Reconsideration of ASLB 830915 Order.No Util Counsel Communicated W/Govt Accountability Project.Certificate of Svc Encl ML20078F8891983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Laverty Will Not Participate in Matters Leading to OL Issuance Due to Previous Employment W/Commissioner Roberts. Certificate of Svc Encl ML20078F8751983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Previous Employment W/Commissioner Roberts Eliminates Any Contribution to Zimmer Case ML20080P0771983-10-0303 October 1983 Motion for Extension to File Appeal Until 10 Days After Svc of ASLB Decision on Miami Valley Power Project Petition for Reconsideration.Certificate of Svc Encl ML20080P0141983-10-0303 October 1983 Petition for Reconsideration of ASLB 830915 Order Denying Miami Valley Power Project Motion to Reopen Record for Admission of Eight Proposed Contentions.Addl Info Provided Since Original Decision.Certificate of Svc Encl ML20080P0481983-09-26026 September 1983 Affidavit of T Devine Summarizing 830919 Discussion W/ C Weaver Re Summary of Interview in Torrey Pines Rept. Weaver Seriously Challenges Completeness of Interview Summary ML20080P0291983-09-26026 September 1983 Affidavit of D Jones for Govt Accountability Project Protesting Torrey Pines Rept Chapter on Cases Studies.Ref to Author Interviews Incomplete & Thus Inaccurate.Analysis of Whistleblower Missed Real Problem of Lack of Freedom ML20080P0671983-09-24024 September 1983 Affidavit of R Reiter for Govt Accountability Project Expressing Dissatisfaction of W/Summarized Interview in Torrey Pines Rept ML20080F2451983-09-13013 September 1983 Memorandum Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions. Torrey Pines Mgt Review & NRC Repts Confirm Project Substantially Correct on Qa.Certificate of Svc Encl ML20080E6921983-09-12012 September 1983 Answer Opposing Miami Valley Power Project 830826 Motion for Leave to Submit New Documents & for ASLB Review of Pending Investigations.Motion Unjustified Attempt to Bend Rules on Late Contentions.W/Certificate of Svc ML20080D2791983-08-26026 August 1983 Motion for Leave to Submit New Evidence in Support of 830603 Proposed Contentions & for ASLB Review of Significant Pending Investigations.Certificate of Svc Encl ML20080C7171983-08-25025 August 1983 Answer Opposing Miami Valley Power Project 830811 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830712 Motion to Compel Discovery.Project Had Opportunity to Brief Issue in Original Motion.Certificate of Svc Encl ML20076A6451983-08-15015 August 1983 Notice of Substitution of Counsel for Amicus Curiae Brief & Appearance Before Aslb.Certificate of Svc Encl ML20024E5591983-08-11011 August 1983 Motion for Leave to File Reply Brief to Applicant & NRC 830803 & 01,respectively,answers Opposing Miami Valley Power Project Motion to Compel Discovery.Assertion of Boundary on Discovery Should Be Briefed.Certificate of Svc Encl ML20024E3941983-08-0505 August 1983 Motion for Leave to File Reply Brief & for Clarification of Responsibility to Duplicate Previous Analysis & Evidentiary Submissions.Util Challenge Frivolous,Heavy on Chutzpah & Deficient on Common Sense.Certificate of Svc Encl ML20077L5161983-08-0303 August 1983 Response Opposing Miami Valley Power Project 830707 Reply Brief Supporting Project 830603 Motion to Reopen Record.Aslb Lacks Jurisdiction to Hear Motion to Reopen to Admit Eight late-filed Contentions.Certificate of Svc Encl ML20024D1381983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion for Protective Order to Withhold Identity of Persons Upon Whose Allegations Project Relied in Seeking to Reopen Record.Motion W/O Merit.Certificate of Svc Encl ML20024D1261983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Actually Is Untimely Appeal from Earlier ASLB Rulings.Relief Sought Contrary to Commission Orders ML20024D1171983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Defer Ruling on Review of ALAB-727 Pending Ruling on Motions to Reopen.No Justification Given to Delay Review for Unrelated Matters ML20080A2721983-07-21021 July 1983 Response to Applicant Motion for Leave to Respond to Miami Valley Power Project Reply Brief.Applicant Should Respond Only to Substance of Proposed Contentions Re QA Program Inadequacy.Certificate of Svc Encl ML20076L4691983-07-15015 July 1983 Motion for Leave to Respond by 830729 to Miami Valley Power Project (MVPP) Reply Brief Re Applicant Opposition to Eight QA Contentions.Mvpp Reply Distorts Record & Applicant Position.Certificate of Svc Encl ML20072N4741983-07-12012 July 1983 Motion to Defer Ruling on Whether to Review ALAB-727 Until ASLB & Aslab Rule on Miami Valley Power Project 830603 & 0712 Motions to Reopen Record to Admit Contentions on QA & Character & Competence,Or Alternatively,To Reopen Record ML20072N4631983-07-12012 July 1983 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence.Aslab Has Jurisdiction Even If ASLB Lacks Jurisdiction to Reopen Record ML20072N4501983-07-12012 July 1983 Reply Brief Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence & Motion to Compel Discovery on Contentions ML20072N4901983-07-12012 July 1983 Motion for Protective Order to Shield Identity of Affiants Providing Portion of Basis for Miami Valley Power Project Eight Proposed Contentions.Certificate of Svc Encl ML20072K7331983-07-0101 July 1983 Answer Opposing Miami Valley Power Project 830629 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830603 Motion to Reopen Record.No Purpose Would Be Served by Permitting Redundant Discussion.Certificate of Svc Encl ML20024B0591983-06-29029 June 1983 Motion for Leave to File Reply Brief,By 830706,to NRC & Util 830630 Answers to Miami Valley Power Project 830603 Motion to Reopen Record to Admit Eight Contentions on QA & Util Character & Competence.Certificate of Svc Encl ML20072F4481983-06-22022 June 1983 Memorandum Supporting Miami Valley Power Project 830602 Motion to Reopen Record to Admit Eight Contentions on QA & Lack of Corporate Character & Competence.Reopening Necessary to Foster Public Confidence in Nrc.W/Certificate of Svc ML20024A6661983-06-20020 June 1983 Response Opposing Motions to File Amicus Curiae Brief in Support of Miami Valley Power Project Motion to Reopen Record for Admission of Eight QA Contentions.Certificate of Svc Encl ML20024A6621983-06-20020 June 1983 Response Opposing Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Untimely ML20076J1361983-06-16016 June 1983 Ohio Sierra Club Amicus Curiae Brief Supporting Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions.Contentions Provide Evidence That QA Problems Exist.Certificate of Svc Encl ML20076J1201983-06-16016 June 1983 Petition for Leave to File Amicus Curiae Brief Re Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions on QA & Character & Competence.Requests Extension of Time.Certificate of Svc Encl 1993-08-11
[Table view] |
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DXMETED f_' 3 M C UNITED STATES OF AMERICA -
'81 0E0 21 A10:50 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD ~, , , M In the M:tter of :
- Docket No. 50-358-OL THE CINCINNATI CAS & ELECTRIC :
COMPANY, et al. :
- APPLICATION FOR OPERATING (Wm. H. Zimmet Nuclear Power : LICENSE m p Station) : g he N
g ECg;yC/)Y, g2 INTERVENOR ZIMMER AREA CITIZENS-ZIMMER AREA CITIZENS (g
gEcp ig .
IO8/s D D
OF KENTUCKY REQUESTS FOR AtMISSIONS BY CLERMONT COUN s
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Intervenor Zimmer Area Citizens-Zimmer Area Citizens of Kentucky (ZAC-ZACK) hereby requests that the following Requests for Admissions pursuant to 10 C.F.R.
12.742 be admitted as to the truth of the matter asserted by posting a response to the request on or before December'30,1981, or be deemed admitted. Pursuant to 10 C.F.R. 52.742(b), where objection is made to a portion of the request, the remaining portion is to be answered within th's t ime stated.
- 1. The village of Felicity, including the schools located within the Felicity-Franklin School District, and the emergency response groups of the Felicity-Franklin police, fire and life squad, is provided telephone service by General Telephone System. y 5
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- 2. Any telephone call from Felicity, Ohio to Batavia, Ohio is a toll, long distanc'e, telephone call.
- 3. Any telephone call from Batavia, New Richmond, Amelia, Mt. Carmel or Withamsville, Ohio to Felicity, Ohio is a toll, long distance telephone esil.
- 4. Any telephone call between the Superintendent of the Clermont County Board of Education or the Clermont County EOC to and from the Superintendent of
. the Felicity-Franklin School Dist rict is a toll, long distance, telephone call.
- 5. The Superin*endent of the Felicity-Franklin School District has three trunk lines fcr in-coming and out going telephone calls to the Felicity-Franklin.
Superintendent's office.
- 6. The Superintendent of the Felicity-Franklin School District is possessed of only telephone communications to school bus drivers of that school
! district not on school site at the t ime that it is necessary to summon school bus drivers to the Felicity-Franklin School site for evacuation of pupils.
- 7. The telephone system in use at the hew Richmond School District and the Bethel-Tate School District is Cincinnati Bell Telephone System.
- 8. The Superintendent of the Bethel-Tate School District has two telephone trunk lines for in-coming and out going telephone calls to the Bethcl-Tate Superintendent's office.
- 9. The Superintendent of the Bethel-Tate School District is possessed of only telephone communications to school bus drivers of that school district not on school site at the time that it is ne;essary to summon school bus drivers to the Bethel-Tate School site for evacuation of pupils, t
a t ?.
- 10. The Superintendent of the New Richmond School District has four tele-phone trunk lines for in-coming and out going telephone calls to the New Richmond Superintendent's office.
- 11. The Superintendent of the New Richmond School District is possessed of only telephone communications to school bus drivers of that school district not on school site at the time that it is necessary to summon school bus drivers to the New Richmond School site for evacuation of pupils.
- 12. There are no d edicated telephone lines existing and servicing the Superintendents of Clermont County, Felicity-Franklin, Bethel-Tate and New Richmond School Districts.
- 13. New Richmond School District has 2,562 students and 17 buses.
14 Each school bus for the New Richmond School District has a seating capacity for 60 students.
- 15. Bethel-Tate School District has 1900 students and 12 buses.
- 16. Each school bus for Bethel-Tate School District has a seating capacity for 60 students.
- 17. Potassium iodide is a blocking agent of the thyroid gland to reduce absorpt ion of radioact ive materialc.
- 18. Potassium iodide, if administered within two nours of exposure to a
i radioactive materials, will substantially reduce in-take by the thyroid gl and of such materials.
- 19. Administration of potassium iodide two or more hours after exposure to radioactive materials is 50 per cent e f fec t ive.
- 20. Children under the age of 13 years, pre puberty, are susceptible to acceptance and retention of radioactive materials by the thyroid gland.
- 21. No school bus possessed by any school district located in Clermont
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County, 0hio, is equipped with a two-way radio system.
- 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 scnools within each district during the course of a school day, i
- 23. Monitoring of evacuees at reception sites, or centers, is to'be accomplished within twelve hours of the evacuee's arrival at such site-i 24. During the presence of a contaminated evacuee at a reception site, or center, and before monitoring, that contaminated evacuee will contaminate the site and those evacuees and Emergency Response personnel present at such site,
- 25. Section 311.07, Revised Code of Ohio, provides for the powers and duties of a county sheriff in the State of Ohio.
t 26. The Clermont County Emergency Response Plan, October, 1981, provides ti.2* zhe 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.
- 27. Section 311.07, Revised Code of Ohio, provides that the Sherif f of I
Clermont County, Ohio may call upon the sheriff of any adjoining county, the mayor or chief executive of any municipal corporation within his county or
adjoining counties, and the chairman of the board of township trustees within his county or adjoining county, to furnish police and fire protection personnel and equipment as may be necessary to preserve the public peace and property in the event of riot, insurrection or invasion.
- 28. An emergency at the Zimmer Station is not a riot, an insurrection or an invasion.
- 29. The Clermont County Emergency Plan, October, 1981, provides no legal authority for the Sherif f of Clermont County, Ohio to direct and control local police, fire and life squad personnel as provided in said plan.
- 30. Section 311.07, Revised Cade of Ohio, does not provide power to the Sheriff of Clermont County, Ohio to direct and control village and township police, fire and life squad personnel.
- 31. Section 4501.01(B), Revised Code of Ohio, defines a motor vehicle as I
any vehicle propelled or drawn by power other than muscular power or powcr collected from overhead electric trolley wires, except motorized bicycles, road ,
rollers , t ract ion engines , power shovels , power cranes , and other equipment used in codtruction work and not designed for or employed in general highway -
transportation, well drilling machinery, ditch digging machinery, farm machinery, t railers used to transport agricultural produce or production materials.
- 32. Section 4301.01(1), Revised Code of Ohio, defines motor bus as any motor vehicle having motor power derigned and used for carrying sore than nine passengers.
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- 33. Section 3313.172, Revised Code of Ohio, provides that a board of education of any city, exempted village, local, county, or joint vocational school district may expend district funds to obtain one or more motor vehicles as defined in 54501.01, Revised Code of Ohio, by purchase or lease, and except as provided in 53327.14, Revised Code of Ohio, any motor vehicle so obtained shall be used solely for school purposes.
- 34. Section 3327.19, 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 l
public or nonprofit private agency or organization delivering services to the aged, to make available one or more 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 or other entity engaged in adult educat ion act ivit ies.
- 35. The buses present in each school district in Clermont County, Ohio are owned and operated by the boards of education of each district.
- 36. No board of education has any contract or agreement with any group, including the Clermont County Commissions, the Sheriff of Clermont County, or the Disaster Services Agency of Clermont County, to provide buses for the ,
transportation of persor s age 60 and older or adult education groups as the same would apply to the Clermont Emergency Plan, October, 1981,
- 37. The Clermont County Emergency Plan ptesents no legal authority for the use of school buses for the transportation of members of the general public and the transportation of the general public during a Zimmer Station emergency is not a school purpose.
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A
- 38. The Clermont County population in Designated Sectors SSE(H) and SE(G)
(as designated by the Clermont County Radiological Emergency Response Plan, hereinafter referred to as the Clermont Plan), consists of a permanent popula-tion of approximately 800.
- 39. The evacuation routes designated for the Clermont residents described in Request #1 corsists of the following alternatives:
(a) that population shall proceed in an easterly direction from the Zimmer Stat ion on a major evacuation route of U.S.
52, through Washiniton and into Franklin Townships, to S.R.
133, the junction of which is noc 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 at Bethel, Gaio, at which pcint they are emerging from the plume exposure area; or (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 cor.tains 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 from the Zimmer Station; or (c) alternatively after traveling on S.R. 222 to remain on that route to its intersection with S.R. 125 near Bethel which evacuation route contains a distance of up to 29 miles
, of travel until said evacuees are beyond a ten mile radius from Zimmer.
- 40. The population east of the access control point on U.S. 52 0.25 mile
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each of S.R. 133, which involves the populations situated east of S.R. 133 and the Village of Utopia and approximately 40 roads serving residents in the Designated Sections SSE(H), SE(G), E(E), ENE(D), and NE(C) of the Clermont Plan, for purposes of evacuation must either proceed into the plume area by proceeding by rt adways intersections with S.R.133 or by following coenty and township roads to S.R. 125 west of Bethel, or proceeding directly into Brown County.
- 41. ,
The Clermont population in Designated Sectors (portions) E(E), ENE(D),
NE(C), NNE(B) and N(A) of the Clermont Plan consists of populations of Monroe and Washington Townships of approximately 1,639 permanent residents.
- 2. The Clermont population described in the preceding Admission are to be 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 (b) they must proceed in a northwesterly direction to 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, thence northerly on S.R. 222 to S.R.123.
4
- 43. The roadways described in the proceeding Admission consists of two state roadways and approximately 38 county and township roadways. These county, township, and two state roadways for travel to an evacuation route are narrow, winding, and hilly at many points.
- 44. With respect to the Clermont populat ion in Designated Sectors N(A),
NNW(R) and NNE(B) of the Clermont Plan, the approximate permanent population is 10,596.
I 45. The evacuat ion routes for the population described in the preceding Admission consists of one state roadway and 27 county and township roadways.
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- 46. The roadways for travel to an evacuation route described in tha pre-ceding Admission are narrow, winding, and hilly in many parts. ,
- 47. The evacuation time estimates for evacuation of the Clermont popula-t ion in the Clermont Plan ranging from 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 f
based upon conditions 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 thant 12 feet in width; -
(g) roads without berm or shoulder, i
- 48. With respect to fire squads in Clermont County, Clermont County has only volunteer fire squads.
- 49. With respect to life squads.in Clermont County, Clermont County has only volunteer life squads.
- 50. The only Clermont County volunteer life squads which have trained paramedics are Goshen and Miamiville.
- 51. At flood stage (Ohio River crest of 53 feet):
l (a) U.S. 52, approximately one-fourth of a mile north of the {
Village of Neviile, is under water and impassable as is Neville Spur and Maple Creek Road for an approximate distance i of one-half mile; ,
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(b) Near the Village of Moscow, just south of S.R. 743 by several feet, U.S. 52 is under water and impassable for an
- approximate distance 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 -snd impassable.
- 52. At a 64 feet Ohio River crest the bridge over Little Indian Creek near Laurel-Moscow Road and U.S. 52 incersection, on U.S. is under water and impass-able.
- 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 Foint Pleasant, including the intersection of U.S. 52 and Indian Road, the intersection of U.S'. 52 and S.R. 232 for en approximate distance of one-half mile; (b) from and including Clermontville Road and its intersec-t ion of U.S. 52 and portions of Clermontville Road approxi-mately 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;
- 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 from approximately one mile east of the Village of Neville to the west and north to within approximately 200 feet of the entrance of the Zimmer Station and within 200 feet to the north of the entrance of the Zimmer Station and continuing through the villages of Point Pleasant and New Richmond; i
. t (b) U.S. to the northwest of New Richmond; (c) the intersections of U.S. 52 and Maple Creek Road, S.R.
743, Laurel-Moscow Road, Indian Road, S.R. 232, Clermontville Altuan Road, and Frank Willis Memorial Road.
- 55. The schools in the New Richmond and Bethel-Tate School Districts of Ohio and the Campbell County School District of Kentucky have no means of communications to bus drivers while the drivers are enroute to or from school.
- 56. The buses utilized for student transportation of pupils in New Richmond and Bethel-Tate School Districts of Ohio and the Campbell County School District i
of Kentucky are 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 3
the af fected schools within the respective dist ricts.
- 57. With respect to the preceding Admission, the New Richmond, Bethel-
- Tate, and Campbell County School buses are located generally during the school day at sites from 5 to 15 miles from the schools which they serve.
- 58. With respect to the various state and county radiological emergency plans, in the event an evacuation of areas surrounding the Zimmer Station is necessary, the evacuees are to be taken to relocation centers. No provisions exist in any of the plans for the immediate screening and segregation of those persons who have been exposed to and contaminated by radiation.
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/NDRE1PB. DENNYSON 200 Main Street Batavia, Ohio 45103 (513) 732-6800 Attorney for Intervenor ZAC-ZACK
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