ML20039A190

Interrogatories Directed Towards Applicant.Certificate of Svc Encl

ML20039A190
Person / Time
Site:	Zimmer
Issue date:	12/04/1981
From:	Dennison A ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY
To:	CINCINNATI GAS & ELECTRIC CO.
References
NUDOCS 8112160340
Download: ML20039A190 (36)

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POLKETED USNPC UNITED STATES OF AMERICA 12g')4/ g _g p NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD ~ ~EECRET/rf

'& SERV:;,

';H In the Matter of CINCINNATI GAS AND ELECTRIC COMPANY, et a1. pygf . h () & 5 k (Wm. !! . Zimmer Nuclear Power Station, Unit No. 1) @ to a

To: Troy N. Conner, Esq.

Conner, Moore & Corbet f. Oggl gqj 1747 Pennsylvania Avenue, N.W. .

. e, $

Washington, D. C. 20006 (g g

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ZAC-ZACK INTERROGATORIES TO APPLICANT s

Intervenor Zimmer Area Citizens-Zimmer Area Citizens of Ken-tucky (ZAC-ZACK) hereby requires the applicant, pursuant to j

10 C.F.R. S2.740(b), to answer separately and fully, in writing, and under oath or affirmation, the following interrogatories on or before December 20, 1981.

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PROPOUNDED INTERROGATORIES

1. State the number of police officers employed full time, ,

stating the police division with whom each is employed as full time police officers who would be involved in an emergency response duty within the plume exposure pathway of the Zimmer power station.

2. State the number of volunteer, auxiliary police officers, stating the police division with whom each is employeil as volunteer, auxiliary police officers who would be involved in an emergency response duty within the plume exposure pathway of the Zimmer power station.

3. State the number of police. officers and identify each police division to which they are assigned who are full time police officers on duty during each shift and each day of the week, stating the number in each police division on duty for each shift during each day of the week, for police divisions which would perform an emergency response in the plume exposure pathway during an accident at the Zimmer power station.

4. As to each of the police divisions which would perform functions of emergency response support group within the plume exposure pathway for the Zimmer station, the number of of f-duty of ficers who would respond, for each police division to call during an emergency at the Zimmer station, including evacuation, and stating the minimum and maximum times required for off-duty officers, both full time and volunteer, to respond to their respective police division for briefing and deployment.

5. State whether full time and volunteer police officers have been advised of the hazards involved in their presence within the plume exposure area of the Zimmer station and whether such officers have

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agreed to accept such risk. .

6. ' State..the. training which-has.been performed.to train police

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of ficers' who would .1x3 involved in the plume ' exposure area of tho' Zimmer-stat'ionito deal with radioactive injured c r. contaminated individuals, tho'means and me' t hods of decontaminating police' vehicles once-con-hminated, and the. direction and. training-which has been given in1 main-taining' traffic control at access control points or otherwise.

7.-:If the foregoing interrogatory is answered in the negative, state the date and type of training to be furnished in the future as it' relates to the questions-posed by the above interrogatory.

8. State the number of1 emergency equipped vehicles (radio, siren and illuminating flashing light) possessed by or. obtainable by each of the police divisions performing emergency response duties in the plume exposure during an evacuation,' setting forth.the information for caph police division.

9. State the number ofLpolice officers employed full time, stating the police division with whom each.is employed as full time-police officers who would be involved in an emergency response duty

-within the ingestion pathway area of the Zimmer power station.

10. State the number of volunteer, auxiliary police officers, stating the police division with whom each is employed as volunteer,

. auxiliary police officers who would be involved in an emergency response duty within the. ingestion pathway area of the Zimmer power station.

'll. State the number of police officers and identify each' police

. division to which'they are. assigned who are full time police officers on. duty during each shift and each dayfof'the week, stating the number in-each' police division on duty for-cach shift during each day of the 2 -

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l week, for police divisions which would perform an emergency-response in the. ingestion pathway area during an accident at the Zimmer power station.

12. As~to each of the police divisions which would perform

' functions'of emergency response-support group within the inqostion pathway area-for the Zimmer station, the-number of.off-duty officers who would' respond, for each police division to call during an emergency

at the.Zimmer. station, including evacuation, and stating the minimum and maximum times required for off-duty officers, both full time and volunteer, to respond to their respective police division for briefing and deployment.

13. State-whether full time and volunteer police officers have +

been advised of the hazards invo'lved in their presence within.the ingestion pathway area of'the Zimmer station and whether such. officers have agreed to accept such risk.

14. State the training which has been performed to train police o Cficers who would be involved in the ingestion pathway area of the Zimmer station to deal with radioactive injured or contaminated individuals, the means and methods of decontaminating police vehicles once contaminated, and the direction and training which has been given in maintaining traffic control at access control points or otherwise.

15. If the foregoing interrogatory is answered in the negative, state the date and type of training to be' furnished in the future as it relates to the questions posed by the above interrogatory.

16. State the number of emergency equipped vehicles (radio, siren and illuminating. flashing light) possessed by or obtainable by each of the police divisions-performing emergency response duties in the ingestion-pathway area during.an evacuation,~ setting forth-the:information for each police di. vision.

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l 17.. As to the police divisions involved'as emergency response groups in both the~ plume and ingestion pathway exposure areas,-state as'to each police division the method and manner of providing dosimeters-and other protective equipment, including a description of the protective.

. equipment to.be distributed to the members ~of each police division, setting forth the time required to distribute such equipment and the place of distribution!for each police division.-

18. State the number of fire department personnel employed full-

' time, stating the fire division with whom each is employed as full time fire department personnel who would be involved in an emergency response duty within the piume exposure pathway of the Zimmer power ' station.

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19. State.the number of, volunteer, auxiliary fire department

. personnel, stating'the fire division with whom each is employed as ,

volunteer, auxiliary fire department personnel who would be involved-in an emergency response duty within the plume exposure pathway of the Zimmer power station.

20. State the number of fire department personnel and identify

.each fire division to which they are assigned who are full time fire departmenbfpersonnel on duty during each shift and each day of the week, tating tile number in each fire division on duty for each shift during each day of the week, for fire divisions which would perform an at emergency response in the plume exposure pathway during an accident the Zimmer power station.

21. As to each of the fire divisions which would perform functions of' emergency response support group within the 31ume exposure pathway for the Zimmer station, the number of off-duty personnel who would' the respond,-for each fire division to call during an emergency at

-Zimmer station, including' evacuation, and stating the minimum and 4 .

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L imaximum. tinies' required. forL of f-duty personnel, both

full time and .

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tvolunteer, to1 respond tottheir' respect'ive fire division ~for briefing i

.'and: deployment.

. :2 2. State whether-full time-and volunteer-fire department personnel have'bcon advised of the-hazards involved in their presence-within the plume:cxposure area of the Zimmer' station and whether such officers have; t

agreed to accept such. risk. .

R2 3. State the training which has been performed to train. fire-department personnel who would be involved in the plume exposure area ,

of the Zimmer station to deal. with radioactive injured cnf contaminated l . individuals, the means and. methods of decontaminating' fire vehicles once contaminated,-and the direction and training which has been given in maintaining traffic control at access control points or otherwise.

24. If the foregoing interrogatory is answered in the negative,

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L . state the date and type of training to be furnished in the1 future as.

.it relates'to the questions posed by the above interrogatory.

25. State the number of emergency equipped vehicles (radio, siren and illuminating flashing light) possessed by or obtainable by each of

.the fire divisions performing emergency response duties in the plume exposure during an evacuation, setting forth the information for each fire division.

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26. State the number _of fire department personnel employed full time, stating the fire division with whom each is employed as full time firefdepartment personnel who would be involved in an emergency response-duty within the ingestion pathway area of the Zimmer power station.-

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27.- -Stato the number of volunteer, auxiliary-fire department

, personnel, stating the fire division with.whom each is employed as L volunteer, auxiliary' fire' department. personnel who would be involved in' ,

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.- ,. si an;emergencylresponsefduty within~the ingestion pathway area of-the 1

'Zimmer power station.

428. LState-the number of-fire department personnel and-identify-

,each fire division to which they are assigned who are full time fire -i Jdepartmen t. personnel on ddty during'each shift and each day of.the week,

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stating the number in cach- fire division on ' duty for each shif t during

- each" day of the week, for. fire divisions which would perform an emergency response-in.the ingestion pathway area during'an accident at the Zimmer -

power station.

29. As to each of the fire divisions which would perform functions of emergency response support group within the ingestion pathway area.for the Zimmer station, the number of off-duty fire depart-ment-personnel who would respond, for each fire division ta call during an emergency at the Zimmer station, including evacuation , and stating the minimum and maximum times required for of f-duty fire department 1 personnel, both full time and volunteer, to respond to their respective fire-division for briefing and deployment.

30. State whether full time and volunteer fire department personnel have been advised of the hazards involved in their presence within the ingestion. pathway area of the Zimmer station and whether such personnel

- have agreed to accept such risk.

. 31. State the training which has been performed to train fire

- department' personnel who would be involved in the ingestion pathway area of-the Zimmer station to deal with radioactive injured or contaminated individuals, the means and methods-of decontaminating fire vehicles i'

. once contaminated, and the direction and training which has been given

'in maintaining traffic control at access control points'or otherwise.

32. 'If the foregoing interrogatory is answered in the-negative, 6

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state the'date and' type'of trainingfto be furnished inI het future as

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it: relates to_the: questions posed by the above interrogatory.

E33. LState the number of. emergency equipped vehicles (radio, siren-and illuminating flashing light) possessed-by or-obtainable by each of-thc1 fire divisions performing-emergency response duties in the. ingestion pathway area'during an evacuation, setting-forth the in' formation for

. each fire division.

-34.. As-to the fire divisions involved as emergency response l

Jgroups in both the plume and ingestion pathway exposure areas, state cas to each fire division _the method and manner of providing dosimeters y and other. protective equipment, including a description of the protective equipment to be distributed to.the members of.each fire division, i

. setting forth the time required to distribute such equipment and the place of distribut. ion for each fire division.

35. State the number of life squad personnel employed full time, stating the life squad division with whom each is employed as full time L . -

l- life squad personnel who would be involved in an emergency response duty within the plume exposure pathway of the Zimmer power station.

36. State the number of volunteer, auxiliary life squad personnel, l

stating the. iife squad division with whom each is employed as volunteer, auxiliary life squad personnel who would be involved in an emergency response duty within the plume exposure pathway of the Zimmer power station.

37. State the number of life squad personnel and identify each life squad division to.which they are assigned who are full time life squad personnel on duty during each shift and each day of_the week, stating the. number in each life squad division on duty for each shift

during.each dayfof the week, for life squad divisions which-would perform an emergency response in the plume exposure pathway during an accident 7

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'at-the Zimmer/ power station.

L3 8 . As toicach f of the life squad divisions which would perform ifunc'tions of emergency response support 1 group within1 the plume' exposure

. pathway,for the Zimmer station, the number'of off-duty personnel who twould respond, for each life squad division:to call during an emergency.

at-the Zimmer station, including evacuation, and stating the minimum and

! maximum times required for off-duty personnel, both full-time and volunteer,,to respond'to their respective life, squad division for briefing and deplloyment.

39. State whether full time and volunteer life squad' personnel-havefbeen advised:of the hazards inyolved in their. presence within'the plume exposure area of the Zimmer station and whether such officers

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have-agreed to accept such risk.

40. State the training which has been performed to train life squad -personnel who would 'lx3 involved in.the plume exposure area of

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the.Zimmer station to deal with radioactive injured or contaminated

-individuals, the means and methods of decontaminating life squad vehicles once contaminated, and the. direction and training which has been given

'in maintaining traffic control at access control points or otherwise.

'41. If the foregoing interrogatory-is answered in the negative, state the date and type of training-to be furnished in the future as it relates to the questions posed by the above~ interrogatory.

42. State the number of emergency equipped vehicles (radio, siren

and illuminating. flashing light) possessed by or obtainable by each'of the life' squad divisions performing emergency response duties in the plume exposure during an evacuation, setting forth the information for- 'i cach life, squad division.

u4 3 . . State the numb'er of life squad personnel employed full time, H

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stating the life squad division with whom each is employed as ful1~ time life squad personnel who would be involved in'an emergency response duty within the ingestion pathway ' area of the Zimmer power station.

44. . State the number of volunteer, auxiliary life squad personnel, stating the life squad division with.whom each is employed as volunteer, auxiliary life squad personnel who would be involved in an emergency response duty within the ingestion pathway area of the Zimmer power station.

45. State the number of life squad personnel and identify each life squad division to which they are assigned who are full time life squad personnel on duty during each shift and each day of the week, stating the number in each life squad division on duty for each shift during each day of the week, for life squad divisions which would perform an emergency response in the ingestion pathway area during an accident at the Zimmer power station.

46. As to each of the life squad divisions which would perform functions of emergency response support group within the ingestion pathway area for the Zimmer station, the number of off-duty life squad personnel who would respond, for each life squad division to call during an emergency -at the Zimmer station, including evacuation, and stating the minimum and maximum times required for off-duty life squad personnel, both full time and volunteer, to respond to their respective life squad division for briefing and deployment.

47. State whether full time and volunteer life squad personnel have been advised of the hazards involved in their presence within the ingestion pathway area of the Zimmer station and whether such personnel

-have agreed to accept such risk.

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n48.- State'1the training'which has been performed to train life

.Sq'uad; personnel who~would be involved in the ingestion pathway area of the Zimmer station toJdeal with radioactive injured or contaminated

' individuals, the means and methods of' decontaminating life squad' vehicles fonce contaminated,.and the direction and training which has.been.given 11'n maintaining traffic. control at access control points or otherwise.

49. LIf the. foregoing interrogatory is answered in the negative, state the_date and type of. training to be furnished in the-future as oit relates to the-questions posed by the above interrogatory.

50. State the number of emergency equipped vehicles (radio, siren and illuminating flashing light) possessed by or obtainable by each of the life-squad divisions ~ performing emergency response duties in the ingestion pathway area during an evacuation, setting forth the information for each life. squad division.

51. As to the life squad divisions involved as emergency response-groups in both the-plume and ingestion pathway exposure areas, state as to each life squad division the method.and manner of providing dosimeters and other protective equipment,-including a description of t$e protective ~ equipment to be distributed to the members of-each life squad division, setting forth the time required to distribute such equip-ment and the place of distribution for each life squad division.

52. State the manner and means by which disabled vehicles, disabled for any reason, which are blocking roadways, will be removed during an emergency at the Zimmer station, including evacuation,.and state whether any agreements have been entered, or.will be entered, with'any individual, business or governmental agencies for such disabled vehicles' removal; and state whether the said untities have

.been advised of the hazards involved in entry into the plume exposure

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area and if, upon such advice, have agreed to accept such risk, or if such information will be conveyed prior to any agreement or under-standing, and setting forth' the identity of said agencies, the equip-ment available, and-if dosimeters and other protective equipment will be issued to wrecker drivers, and if so, the place and manner in which such protective-equipment will be distributed.

53. State whether emergency response personnel, including CART, TANK and school bus drivers and other drivers set forth in emergency plans for the evacuation of the handicapped and olderly, as well as injured, have been advised of the hazards of entering the plume exposure area.during evacuation for the purposes of transporting individuals requiring transportation and if upon such advice the respective drivers have agreed to accept such risk, and if not, will such information be presented to such individuals in the future,.and if so, when, where and the general tenor of the information presented.

54. State the place, manner and means by which the emergency response personnel involved in functions within the plume exposure area will be furnished dosimeters and other protective equipment during a Zimmer station emergency, including evacuation, as to those emergency response personnel entering the plume exposure area.

55. State the time period between announcement of a Zimmer station emergency requiring activation of emergency support group personnel and the physical reporting of such personnel to their duty stations for briefing and deployment within an emergency support function, identifying each group of emergency response personnel and the minimum and maximum times required from announcement to presence at duty station.

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56. State the authority by which the state National Guard may be' activated for regular duty during an emergency at the Zimmer station and state the name of the individual or individuals who are authorized

'to activate the National Guard.

57. State the units of the state National Guard, and the priority for activation, which will be activated during an emergency at the Zimmer station, presenting the unit designation sufficient for identifi-cation, the location of each unit, the number of personnel in each unit, the rank and name of the commanding officer for each unit, the training presented to such Guard members to perform emergency response duties, whether the Guard members have been advised and have accepted the hazards involved in entering into the plume exposure area, the number and type of vehicles and aircraft within the control of each unit, and the time period between the announced activation of each unit and the assembly of each unit, and the time period from assembly of c'ach unit, excluding briefing, to the deployment of each unit as a support group within the vicinity of the Zimmer station, including briefing, and the vicinity of the deployment of each unit.

58. State the frequency, duration and place (location) within the years 1982, 1983, 1984, 1985 and 1986, on an annual basis for each unit described in the above interrogatory, in which each unit will be on active duty, e.g., two-week summer camp, maneuvers.

59. State the names, positions and responsibility of state and local disaster service agencies, or disaster emergency service, personnel who are members of the state National Guard or active military reserve members, and state the periods in which each named and identified individual will be responsible for periods of active duty, on an annual 12

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• 4 basis,1with such. military units, identifying the individual's rank, unit,.and pe'riodstof' active duty with the unit in the years 1982, 1983, 1984,L1985 Land.1986; and:as to each individual performing military duties on"an active status,,the name of-the individual who would be replacing

- and-performing his/her duties in the DSA,.or DES, in the event of . a

. Zimmer_' station emergency.during the presence of the primary individual while on active duty in the military.

60. .In the' event of.a declaration of war, or, and including, the activation of the state National Guard to federal service on an extended basis, what personnel, by appropriate number and equipment,'will be utilized to fulfill the duties of the state National Guard designated as support units in the state'and local emergency plans, during the military unit's absence due to federal service?

61. State the name and unit of police officers,-fire and life, or. rescue, squad personnel included in the emergency responso groups within the stato and local plans for a Zimmer station c.nergency who are members of the state National Guard or who are members of an active military reserve unit, stating the military unit for each individual and the periods of. active duty for which each individual is obligated.

62. State for each hospital performing an emergency response group service, for contaminated and radiologically injured individuals as to whether that hospital has an existing disaster plan; and if answered in the affirmative, present an explanation in general detail of-the general tenor of such plan, and attach a copy of the plan to

-the response to these interrogatories.

63. As to each-involved hospital referred.to in the above interrogatory, state the date of the last revision to the hospital's disaster plan, as that plan pertains to the treatment of radiologically

injured persons, state when the plan was last. tested.by an exercise or 131

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drill, ? state ' the of ficial and complete results of such exercise-drill, including' faults noted, and'the anticipated. future-revision of said~

' plan,.if any. -

6 4 .- - State for eachlof the hospitals' referred to.in'the~ foregoing, what plans for nuclear disaster.are presented, including emergency _

-room-setup and. isolation; whether emergency. treatment includes separate-

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entrance'and area for radiologically injured individuals; presence and.

availability for - segregation and radiation confinement; whether such

. plan has been approved by the appropriate-accreditation group; and

' describe the physical location forothe decontamination facility.

65. ' State and identify by location other hospitals included'in

-the emergency plan which can provide' additional assistance, by way'of personnel, equipment and patient transfer, including.a description of' the equipment to satisfy such' obligation by each hospital.

66. State specifically_and describe in sufficient detail the-facilities present'in each hospital within the emergency response plan for the treatment of persons exposed to ionizing radiation, including the number of patients which can be treated and hospitalized during a single event; and stating the manner and means other than area life,.

or rescue, squads and fire units which would be availabic ty each hospital for transporting injured persons to other facilities during an emergency at the Zimmer power station.

67. As to each hospital referred to_ in the emergency ,,: an', has'a specific person been designated and' advised as to the supervision of a specific medical-department during a nuclear accident; stating-whether there is a written document specifying such people in a. supervisory position, . identifying by, name, medical specialty, and responsibility Lof'such individuals.

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68. As to cach hospital within the emergency plan, identity the persons in the employ of_each hospital who have been trained in nuclear

-medicine, including each' individual's classification and experience,

.when auch training was provided, how often refresher' training will be provided, whether auch individuals have been aavined in writtng au to

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their autien, and whether each 1ndividual has acknowledged acceptance of such dutten.

69. What monitoring devices,and the number, including a description, are preacnt in each hospital within the emergency plan for which the Individual patient may be assessed; and state the identity, clasalfica-tion and qualifications ot the hospital personnel wno have the ,

responurbility to read and interpret auch monitoring devicen.

70. As to each hospital within the emergency plan, state whether that hospital.han psychiatric support, obstetrics care, including upecial equipment and personnel; pediatric care, including upecial equipment and personnel for special medical problems; nucicar medictno; and state whether the emergency room personnel have been trained in nuclear medicine and, if no, state the number of hourn for auch training. An to each hospital in the emergency plan, state the number of hospital employees on duty for each shift and their respective claustlicationu; and state the number of nospital peruonnel on call within the hosp 1Lal dinanter plan, including all departmenta.

71. State the contact between eacn hospital included in the emergency plan with a county or stato dinanter servico agency, or any representative of C.G.& E., concerning the inclusion of each hospital in an emergency plan.

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72.- As to each hospital within the emergency plan, state and identify the ho'spitals which have signed letters of agreement between themselves for' exchange of services, designating what services are included in the exchange, and attach to the response to these interroga-tories copies of such letters of agreement.

73. As to each hospital within the emergency plan, state the identity of the individual responsible for initiation of hospital evacuation when advised that the maximum permissible dose level of radiation has been reached and that ovacuation of the hospital is required.

74. As to each hospital within the emergency plan, state the amount of potassium iodide which will be present and avaiiable for dis-tribution to hospital staff and patients during a Zimmer station emergency.

75. As to each hospital within the emergency plan, state whether that hospital is prepared to initiate or will cooperate in a population registry for tollow up investigation of the health effects to the population following excessive dose radiation to that population.

76. As to each hospital within the emergency plan, state the hospital policy tor individuais who present themselves at the hospital for decontamination rather than presenting themselves to a local decontamination center, including tne identity of the hospital personnel responsible for making a decision in this area, and identity the individual and the quailfications and training.

77. State as to each hospital within the emergency plan the bed space, requisite medication available, capability of screening ,

treatment and isolation of radiologically injured persons.

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78. State whether local and state agricultural extension oftices and boards of health have had input i.nto the preparation of t.he state and Elocal emergency plans as tho' name bears upon cocperation and acceptance of emergency support group responsibilitic ., and, if so, state as to each the amount of time and general tenor of such input.

79. State the manner and degree of training, including the hours of training, provided to agricultural extension service personnel and local board.s of health, pertaining to current information about radiation hazards and contamination, including the disposal of agrt-cultural products contemplated for human consumption.

80. State the manner and means by wnich personnel of the agri-cultural extension office and local boards of health will disseminate public information to farmers and individuals growing or obtaining foodstuffs, game, fish, crops and milk, including a description of the actions to be taken during and af ter a radiation release at the Zimmer station sufficient to contaminate for human consumption the above-coscribed items; and including the manner and means by which poultry and livestock alternative feed source (feed kept under cover) will be obtained, maintained and supervised; the availability and distribution of uncontaminated feeds for poultry and livestock; the means and manner by which livestock will be sheltered and housed; the proper means of cleaning, storing and preservation of poultry and livent ock feeds, methods and directions for decontaminating livestock and poultry and the respective feeds; the manner and means of public intormation, including a notification to each ot the involved individuals; and stating the person or persons responsible at each agency for the dissemination of infori.ation to the involved population and the monitor-ing and supervising of decontamination, sheltering and other protective-actions.

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- 81. State the manner and means by'wh'ich the agricultural i  ! extension service. office and the boards of. health have for the prepara-Wion:and maintenance of_ maps; establishing detailed crop _ presence information, livestock, pou'ltry, and.the facilities processing agri-

' cultural l products.

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DB 2. - State what provisions'have'been implemented by the agri-

.ctiltural extension :scrvice of fice for the. presence or maps identifying locations of dairy herds and the faciltties processing. milk products.

.. State the' plan and' provisions made by the agricultural _ extension service agency and boards-of health for the control of insects and rodents fo'llowing radiation contamination from the Zimmer station.

83. As to the agricultural' extension.scrvice agency and tne boards offhealtn, describe the procedures for collecting _naseline data on radiation concentrations in milk, fish and agricultural products intended for human consumption.

84. State'the location of barns and stables housing horses, and

.the number of horses present in each, as the same is present in the plume exposure area, and as the same is present in the food 2ngestion area.

85. State the_ location of barns and stables housing goats, and the number of goats present in each, as the same is preses.t in tne-plume exposure area, and as the same is present in the food ingestion area.

86. State the location of barns and stables housing sheep, and the number.of sheep present in each, as the same.is present in the plume

-exposure area, and-as-the same is.present in the food ingestion area.

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87. State the location of barns and stables housing pigs, and 1 1

the number of pigs present in each,: as tne same ts present .in the plume exposure area, and as the same is present_in the food. ingestion area.

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88. State the location at barns and stables housing beef cattle, and the number of beer cattle present in each, as tne same is present in the plume exposure area, and as the same is present in the food ingestion area.

89. As to interrogatories 84, 85, 86, 87 and 88, state the manner and means by which the agricultural extension service and the boards of

-health will disseminate intormation and monitor such animals, their feedstuffs, and, in the circumstance of horses, the policy to be imposed for the vanning at horses out of the respective emergency zones when evacuation is required.

90. As to each local plan, state the current permanent population in each designated sector and the current evacuation route to be followed

-by each sector, including a description or the alternative route in the event that the wind direction present at the time of evacuation directs the plume in the same direction as tne primary evacuation route.

91. State the time for driving in each designated sector, for evacuation, excluding times for notitication and preparation for the evacuation of the population within each sector under the following conditions:

(a) ice storm witnin 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of the announcement to evacuate; (b) ice storm within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of the announcement to evacuate; (c) ice storm within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the announcement to evacuate; (d) snow accumulation of 2 inenes within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of the announcement to evacuate; (e) snow accumulation of 2 inches within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of the announcement to evacuate; 19

0 *

(f) snow accumulation of 2 inches within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the announcement to evacuate;

-(g) snow accumulation of less than 2 inches within 3 nours of the announcement to evacuate; th) snow accumulation of less than 2 inches within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of the announcement to evacuate; s

(i) snow accumulation of less than 2 inches within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of tl:e announcement to evacuate; (j) snow accumulation of 4 or more inches within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of the announcement to evacuate; (k) snow accumulation of 4 or more inches within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of the announcement to evacuate; (1) snow accumulation of 4 or more inches within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the announcement to evacuate; (m) snow accumulation of 4 or more inches more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the announcement to evacuate.

92. During the periods of the crest of the Ohio River at flood stages experienced from January 1, 1964 to the present, state the roadways and locations thereof, which were rendered impassabic for automobile passage, the years and specific dates thereof in which the same occurred and identify the flood stage in teet of the Ohio River in each circumstance.

93. During periods of snow accumulation, on an annual basid7 for each year from January 1, 1976 to the present, state the roadways and location which were rendered impassable for automobile passage, the years and specific dates thereof in which the same occurred, the amount of snowfall, and the period of time in which each road remained impassable for automobile passaga.

94. State the time required for the individual, or family, tc be ready to commence operation of the motor vehicle utilized for trans-portation in an evacuation, where the individual, or family, has a vehicle present at the home.

20

T 4 8

'95.c LStateu the;- time lrequired ifor the : Individual, or tamily, to

' be ready to; commence: operation of the motor vehicle ut.112ed for trans-portationfin an' evacuation 6 where the individual , or family, does not -

fhave*a vehicle presenL at.the home,.under the..following circumstances: '

.(a) the -: family vehicle will be driven ' to the - home to evacuate the family; (b)' other transportation is dispatched to the residence' to evacuate-that individual or family. ,

96. Identify by name the unimproved, dirt roads, present in each

. designated sector of:the plume exposure area and ' state the following: ,

'(a) the width of ' uchs road, the ~ maximum miles per hour -3 that.one may safely drive a vehicle on such road,-

the distance of such road to its intersection with an improved roadway', and the number of residents serviced and furnished by said unimproved, dirt road;.

(b)- whether the road is cleared of ice or. snow accumulation

by any township, county or sttue road service agency, and 'if so, the period of time after ice'or1 snow accumu-lation in which clearing of said roadway is~ performed.

97. Identify by name the township roads present in each designatedL sector of the plume exposure area and state the following:

l L (a) the width of such road, whether it is conterlined, the

! maximum miles per hour that one:may safely drive'a

! vehicle on such road, the distance of such road to its intersection with a county road, and the number of ,

, residents serviced and furnished by said township road; (b) whether the road is cleared of ice or snow accumulation

~

l by any township, county or statc road service agency, and if so, the period of time af ters ice or snow accumu .

lation in which clearing of'said roadway is performed.-

98. - Identify by name the county roads present in each designated sector of the plume exposure ~arca and state the follow'ing :

l (a) the width or such road,.whether it is conterlined, the maximum miles per hour that one may safety drive a i vehicle on such road, the-distance of such road to its o intersection with a state road, and the' number of l residents serviced and furnished b'y said county road 1

~'

21.

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(b) whether the road is' cleared of ice or snow accumulation by any. township, county or state road service agency, and if so, the period of time after ice or snow accumu-lation in which clearing of said roadway is performed.

99. Identify by name the state roads present in each designated sector of the plume exposure area and state the following:

(a) the width of such road, whether it is centerlined, the maximum miles per hour that one may safety drive a vehicle on such road, the distance of suen road to its intersection with a federal roadway, and the number of residents serviced and furnished by said state road; (b) whether the road is cleared of ice or snow accumulation by any township, county or state road service agency, and if so, the period of time after ice or snow accumu-lation in which clearing of said roadway is performed.

100. Identify by name the federal roadways present in each designated sector of the plume exposure area and state the following:

(a) the width of such road, whether it is centerlined, the maximum miles per hour that one may safely drive a vehicle on such road, the distance or such road to its intersection with another roadway, and the number of residents serviced and furnished by said federal road; (b) whether the road is cleared of ice or snow accumulation by any township, county or state road service agency, and if so, the period of time after ice or snow accumu-lation in which clearing of said roadway is performed.

101. As to each designated sector, state whether there will be traffic control points established at intersection or roadways within the sector, excluding those areas designated as access control points manned or unmanned in the October 1981 emergency plan, and if sucn traffic control points are established, by what police agencies will traffic control points be manned.

102. If there will be no roadway intersection traffic control points manned.by police officers or other support personnel, excluding those access traffic control points set forth in the October 1981 emer-gency plan, state whether vehicular accidents have been considered and reflected in evacuation time estimates.

22 w . - - --

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103. If tho'above interrogatory has been answered in the'affirma-

. tive,"statd!the additional time' estimated for traffic congestion, removal of. vehicles,-attendance of injured', if any, and means by which those

- involved in vehicular contact .will be transported to a reception center.

104.- State the number of schools, . identifying each by name and location, that are situated within-the plume exposure pathway'of-the emergency' planning zone and presenting the distance by air of each school from-the'Zimmer station.

105. State as to each school identified in the above interrogatory the number of students and faculty and school personnel situated in each school.

106. -State as to each school identified in the above interrogatory, the number of school buses presented for the evacuation of the student population at each school, the number of seats available in each school. bus, the location of each' school bus during school hours and the distance of each ~ bus parked during said period by roadway mileage fromeach school.

107. State as to each school bus identified the age and mileage of each bus, its number of days out of service for repairs during the past school year and during the present school. year.

108. State the number of routes, or trips, as to each school that each bus is required to take during the morning hours of the school day for transportation ~of students to school, the time enroute, the-time interval trom the conclusion ot the morning transportation to the commencement of afternoon transportation of students to their nome, the number of-trips, or routes,_and the time period in which students are

transported from school to home.

109. -State.the number of drivers, as to each school, who have Lother modes of employment during the school day, identifying the place

~

. ~

23

_ . . . .;=... . .-.- a

e and type of employment and the ~ availability of such drivers to respond to the school for evacuation.

110. State the method and manner of notifying school bus drivers to respond to the school during the school day in the event of evacuation of the school.

111. State the method and manner of notitying school bus drivers during an enroute transportation (during morning or evening route) of school children to or from the school that an evacuation or in-shelter notification is present to advise such drivers of corrective actions required, as to each school.

112. State the plan of evacuation and the time periods involved where students are located at the individual school and other students are in buses either being transported to or from school at the time tnat an evacuation is declared, including tne method or communicating and directing school bus drivers during such a situation.

113. State whether school bus drivers operating buses in the plume exposure area will have dosimeters and other protective equipment, and if so, the identity of such equipment and the place and manner ot distribution of such equipment, and the time period involved in such dis-tribution.

114. State whether any school bus involved in plume exposure evacuation will be equipped with two-way radio and, if not, state the reasons for not providing-two-way radio as to each bus.

115. State whether bus drivers of schools present in the plume exposure area have been advised as to the hazards or radiation and what training, if any, has been provided to such drivers; and if the drivers have been advised of the risks, have such drivers agreed to accept such risks.

24 -

. =

116. If bus drivers have not been advised of the hazards of radiation, will they be so advised in the future and, if so, when and under what circumstances, together with the general tenor of such information.

117. State the number of school bus drivers in each school within the plume exposure area that reside within that area and as to whether cuch drivers have agreed to transport school children or undertake the evacuation of their family during an evacuation.

118. State as to each' school present within the plume exposure area the time involved in discussion with disaster service agency personnel or agent and personnel of C.G.& E. for the preparation of emergency plans for evacuation of school children, setting forth the means and manner of evacuation in the event of a Zimmer station etargency as set forth in existing emergency plans or, if not, when the operating procedures will be presented as to school evacuation, attach to the response of these interrogatories tne draft form or such plan to date of response.

119. State as to each school present in the plume exposure area the information presented to either the disaster service agency involved or to C.G.& E., or both, as to the requirements and circumstances of each school for evacuation, its school buses, location of drivers, times within which students can be evacuated and other matters pertaining to affording _information concerning evacuation of each school, setting forth the information so conveyed and to whom conveyed.

120. State the number of meeting and time periods involved (duration 1

of meeting and date of meeting) for coordination ot the schools within cach school district within the plume exposure in which district and county superintendents were present, as well as non-school personnel, 25 -

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1. otating the. identity.of the individuals in attendance and the general' Eenor:of-tho' matters discussed.

121'. 1 state the type of communication to be employed during an emergency at the Zimmer station, including evacuation, between school ~

~

cuperintendents and school principals and EOC and the EOF, for the purposes of directing prot'ective action and each school being advised of the protective action required, including the time necessary for the communication of such information after knowledge or the event and d'etermination of the protective action.to be taken, together with any difficulties experienced or potentially to be experienced in such communications pursuant to the type of communication device elected.

~

122. State the manner and time necessary for the removal and transportation of school children present in a school to be utilized-in an evacuation for the reception of school children or the general population, or both, during an evacuation.

123. State as to each receiving site school the number or students present in each school, the number of school buses present, the time required to transport students to homes and the plan present, or to be presented in its current draft form, as to the means, manner and times involved in the removal of school children from school reception sites.

124. State whether school buses within schools outside of tne

.ptume: exposure area will be utilized for evacuation of school children or general population within the plume exposure area, and, if so, whether the school bus drivers involved have been advised of the hazards of radiation and, if so, if such drivers have accepted such risks and, if not so advised, will such drivers be advised in the future, stating the'date and general' tenor of such advice.

26 -

t

'f.

125. State the means to be taken by each school within the plume exposure area in the event of evacuation where a parent or parents present themselves to the school for purposes of evacuating their child uor children located at such school, including wnat authority, if any, is present by school personnel to deny a parent the opportunity of removing the child from the school for evacuation by personal automobile and refusing to permit the school to evacuate the particular child by school bus.

126. State whether at any school within the plume exposure area there is present the potentiality for traffic congestion and traffic blocking of school buses existing or entering the school parking areas preparatory for transportation of school children during an evacuation where parents arrive at sucn school with private vehicles to remove children from the school.

127. State, in the instance of transportation of school children to their.home during the first advice of an emergency at the Zimmer station, but not requiring protective action of sheltering or evacuation by closure of the school, what means are present for the evacuation or that school cnild from the home in the event of further emergency requiring evacuation where the child's parents are both away from the home for reasons or employment, or otherwise, including notification or awareness of emergency response personnel of the presence of school children at the home without adult supervision, 128. State whether each school in the plume exposure area will present any meeting with parents to advise of the nature and circumstances of radiation exposure, the plans for sheltering and evacuation and the transmission of any policy concerning withdrawal of a child from the school by parent in the event of accident at the Zimmer station and, 27 ,

p. .

1.-~__-.__ . _____. - . ,- - ~. -

it not, state whether the school will distribute any written material to the parent pertaining to the foregoing and, if whether a meeting or written information is to be disseminated, set forth the general tenor of such information and, if in written form, attach a copy to the response to these interrogatories.

129. State the time from notification that a school is to evacuate, as to schools within the plume exposure area, to the point that buses are available and ready for boarding, to the time period involved for the final cus' evacuating children to be without tne plume exposure area.

130. State the schools' plan for the administration of potassium iodide to school children, including the time after exposure to admin-l 1stration and the place of administration and by whom the blocking agent will be administered.

131. State the number of days, as to each school within the plume exposure area, that the school was closed in the scholastic years l

1975-76, 1976-77, 1977-78, 1978-79,1979-80, 1980-81, due to impassable roadways within the area of each school and the inability to transport children to or from school (where school was closed during school hours because of advancing inclement weather).

132. State the plan for each school within the plume exposure area to conduct evacuation d_211s, i.e., comparable to fire and tornado drills currently being employed, the number and frequency of such drills on an annual basis, and the time involved in such drills to permit buses to arrive at the school grounds and for the students to be boarded on cuch buses preparatory to transportation from the school.

133. State the plan for each school in the plume exposure area for training of school personnel and students as to the protective action 28 C- -

-_______ = = -- - -

to be engaged during an emergency at the Zimmer station.

134. State what routes,.and alternative routes,_have been selected.

for transportation of school children during evacuation at each school situated in the plume exposure area.

135. State whether the thyroidgland is a suscept-ible organ of the human body to accept and retain radiation exposure.

136. State whether potassium iodide is a blocking agent which may be administered therapeutically and protectively for the protection of the thyroid gland of an individual exposed to doses of radiation, of the dose levels to be experienced during an accident at the Zimmer station' requiring evacuation of the population within the plume exposure pathway.

137. State whether the adminis~tr&tlon of potassium iodide as a protective thyroidblocking agent is diminished by the passage of time in hours after exposure, as to the effectiveness of the thyroid blocking agent potassium iodide.

138. State whether radiation exposure of the degree contemplated under evacuation circumstances is a viable threat to post- 'and pre-puberty children.

139. State the plans, policy and manner in which, including times after. exposure, that khe potassium iodide will be administered to children and members of the adult population, either or both, who are exposed to radiation releases within the plume exposure pathway.of the Zimmer station during-a radiation release requiring evacuation of the

. general population.

140. If potassium lodide is not.to be administered to the general adult population and children involved in the plume exposure pathway of .

the Zimmer station- during radiation release requiring evacuation of the populat on,1 the reasons that potassium iodide will not be administered

~ to such population. '29

-. -.. 3

s

• 141. State the period of time af ter exposure and contamination to radiation release members of the general population will be decon-taminated, stating the place, manner and method of such decontamination.

142. If decontamination of contaminated individuals will not be performed until approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after contamination and presence at a reception site, state whether the presence of an undetected con-taminated person will contaminate the persons present at the reception site and, if so, the manner and means by which the popula tion of the l

reception site and the reception site itself will be decontaminated. )

l- )

143. State the protective actions to be taken for the confinement i r

i or removal of waters used in decontaminating people and equipment, including the protective actions to insure against the contamination of sewer systems.

144. State the manner of identifying contaminated individuals who do not appear at and receive monitoring at reception sites, i.e.,

those individuals who are contaminated by radiation but proceed to an ]

area other than a reception site location.

145. State the location and identify the number of head in milking herds of dairy cattle, present in the plume exposure p.sthway and the

.i ingestion pathway of the emergency planning zones, specifying which zone each identified dairy herd is located, the bulk pounds of each bulk tank receiving and storing milk and the period between removal of bulk milk,-and the processing facility to uhich each bulk milk tank will be delivered for processing of such milk, and the protective actions to be employed in sampling, inspecting and monitoring such milk, both-at the farm site and at the site of the processing facility. ,

146. State'the manner and means, identifying by number and location of each individual within each designated sector of the plume 30

_ _ _ _z _-- = _ _i---r - - - - - - - - -

exposure pathway'that will require some form of public evacuation to evacuate such individual, setting forth the means and identifying the

'public transportation to be deployed and the individual responsible for the maintenance of the roads, identifying those individuals requiring

.public transportation during evacuation.

147. Where a designated sector within the plume exposure pathway is to-be serviced by an emergency response support group totally

~

comprised of volunteer personnel, state and identify the voluntary

-personnel who reside and have families within the plume exposure area and whether such individuals have agreed to undertake their voluntary assignments of emergency protective action and would not proceed to their homes to assist in and be a party to the evacuation of their own families during an evacuation situation due to radiation release at the Zimmer station.

148. State the minimum and maximum air speed by miles per hour experienced at the Zimmer station, together with the frequency of the wind direction as it would involve the respective designated sectors

'cet forth in emergency plans,. October 1981.

149. State the h,!ight above ground level of the stack, or stacks, pr6senh at* the Zimmer station and capable of radiation releases during

~

accident or otherwise.

150. State what ef fect, if any, terrain elevational differences of 200, 300, 400 and 500 feet above ground level of the Zimmer station

.in the nearby environs to and including 15 miles from the Zimmer station as the same would influence plume exposure pathway at respective distances of 1, 2, 3, etc. to 15 miles from the Zimmer station as affected by

~dif ferent eleyational planes. .

151. State the air miles from the Zimmer station to the Clermont-31

._ -~ ,

._ , . _ . . . r . _ .

s e.

Brown County line where that line intersects nullskin Creek.

152. State the air miles from the Zimmer station to the inter-section of;the Clermont-Brown County line at Richey Road.

153. ' State the distance in air miles from-the Zimmer station to

. the Clermont-Brown County line at its intersection with S.R. 774 in the near environs of the Village of Maple.

154. State the distance in air triles from the Zimmer station to the Clermont-Brown County line where it- intersects Leonard Road.

155. State the distance in air miles from the Zimmer station to the Clermont-Brown County line where it -intersects with S.R. 756.

156. State the roadway vehicular traffic capacity, roadway widths, whether such roadways are improved or unimproved, the width of each roadway, as the same is located in Brown County, Ohio and situated.in a sector from the Ohio River to S.R. 125 and three miles east of the Clermont-Brown County lines.

157. State the presence of any protective action to be taken by the population and governmental of ficials of Brown County, Ohio, which is contained in any state or local plan presently in existence, which deals with emergency planning preparation and implementation for the health *and safety of the population of Brown County, as the same pertains to_ emergency planning of the plume exposure pathway and food ingestion pathway from the Zimmer station.

158. State the agricultural products present within the sector

- identified in interrogatory 156 as to vegetation grown for human or animal consumption, the presence of poultry, cattle, pigs, sheep and goats, the location of the same, and the agricultural entension service agency.and board of hcalth which would bear the responsibility for the-32 v -e-,. .. v

-mmc ,

o . * ,

monitoring of. animals, animal feeds and food to be processed, or processed, for human consumption within the sector identified'in interrogatory-156.

159. State whether or not NUREG/CR-2260, NUS-3854, " Technical Basis for Regulatory Guide 1.145, ' Atmospheric Dispersion for Potential

. Accident Consequence Assesments at Nuclear Power Pl ants '" , has been applied to the Zimmer station.

160. If interrogatory 159 is answered in the affirmative, state the definition of EAB, exclusion area boundary, and LPZ, low population zone, applied by the utility and identify each boundary by air miles from the Zimmer. station, together with the definitions applied for the terms " f umigation" and "non-fumigation"', the wind speed and direction frequencies applied as experienced at the Zimmer station, the application of lateral and vertical plume spreads, and state whether Zimmer station falls within the regulatory guide-model of possessing usual terrain, waterways and meteorological conditions, establishing the boundaries based upon the model, or the boundaries established in utilization of unusual terrain, nearby waterways and meteorological conditions, and ctate the distances beyond each established boundary where the concen-trhsio'n of th'e plume radiation due to low wind speeds and stable atmos-pheric conditions would no longer present radiation doses possessing the capability of harmful health and safety effects to the population; state whether terrain obstacles for stack and ground releases in any manner affect the boundary distances for determining the diffusion of the plume concentration;and state all values used in the calculations undertaken by applicant; and set forth to the response to these' inter-rogatories_all calculations made to establish requisite boundaries and the concentration of plume dispersion within each area, especially in 33

t. 1 __ a. . _. _ .- ---- - - - rg---- - ~r

e -

s "s e 6 the sectors northeast and southeast of the Zimmer station and into Brown County, Ohio.

161. Statu what effect, if any, elevational~ ranges of 400 to 500 feet above the Zimmer station would have upon dispersion of radioactive particles during a Zimmer station accident of a degree sufficient to' warrant evacuation of the general population.

162. State the manner and means and attach the calculations employed-by Stone & Webster in its estimated time evacuation con-siderations as the same was applicable to roadway widths and type of roadways present in the plume exposure area surrounding the Zimmer s ta tion.-

163. State the manner and means by which information, exclusive of the " Circle of Safety" publication, will be disseminated to the permanent and transient populations of the plume exposure area of the Zimmer station, identifying the mode of distribution to the public, i.e., sign, written publication, etc.

164. State the educational readability necessary to comprehend the publication " Circle of Safety" which is set forth in each local eme,rgency plan, October 1981.

Respectfully submitted, -

/ ,) / -

,f /

- Y <

ASDRE TB. DEMNI60N Attorney for.ZAC-ZACK

-Dated at Batavia, Ohio this 4th day of December, 1981.

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34

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. UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING UOARD John !!. Frye, i 1I,' Chairman M.. Stanley Livington, Member Frank F.. Hooper,. Member In the: Matter of  :

CINCINNATI' GAS AND ELECTRIC  :

COMPANY, ET AL.  : DOCKET NO. 50-358 (William'. II. Zimmer Nuclear  : APPLICATION FOR Power Station)  : OPERATING I,ICENSE CERTIFICATE OF SERVICE It is certified'that the ZAC-ZACK interrogatories to the applicant were posted by U.S. mail to the persons indicated-below, and where asterisk is noted, personally delivered, this 4th day of December, 1981.

Charles A. Ila r t h , Esq.

John H. Frye, III, Esq.

Chairman, Atomic Safety ,

U.S. Nuclear Regulatory Commissiod and-Licensing Board Room MNill! 9604 U.S. Nuclear Regulatory 7735 Old Georgetown Road Bethesda, Maryland 20014 Commission Washington, D.C.. 20555 Dr. Frank P. Ilooper, Member Troi N. Conner, Esq.

Atomic Safety and Licensing Conner, Moore & Corbet Board 1747 Pennsylvania Avenue, N.W.

School of Natural Resources Washington, D.C. 20006 University of Michigan Ann Arbor Michigan 48109

- Dr..M.. Stanley Livingston Atomic Safety and Licensing Appea Member, Atomic-Safety and Board Licensing' Board U.S. Nuclear Regulatory Commissio!

20555 m 1005. call e . Largo Washington, D.C.

Sante Fe, New Mexico Docketing and Service Section Atomic Sa fety and Licensing Boar @

Office of the Secretary Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissis

.W ashington, D.C. 20555 Washington,'D.C. 20555

• Mary Reder William J. Morgan, Esq.

Box 270 General Counsel Route 2 Cincinati Gau & Electric Co.

California, Kentucky 41007 P.O. Box 9t30 Cincinnati, Ohio 45201

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• John D. Woliver, Esq.

• Jumos II. FeIdman, Jr.. Esq.'

P.O. Box 47 Fifth Level 550 Kilgore Street 216 East Ninth Street-Batavia, . Ohio 45103 Cincinnati, Ohio 45202 George E. Pattison, Esq. . David K. f t.i r t in , Esq.

462 E. Main Street Assitant Attorney General Batavia, Ohio 45103 Acting Di rect.or Division of Enviromental Law Office of the Attorney General 209 St. Clair Street Frankfort, Keptucky 40601 y .

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ANDRf5i D.' CNNISON 200 Main reet Batavia, hio 45103 (513) 732-6800 Attorney for Intervenor ZAC-ZACK O

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