ML19338C459

Comments on Ky Div of Emergency Svcs Portion of Facility Evacuation Time Estimates:Study Does Not Reflect NUREG-0654 Guidance

ML19338C459
Person / Time
Site:	Zimmer
Issue date:	08/08/1980
From:	Reder M MENTOR, KY
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8008150436
Download: ML19338C459 (2)

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Docket No. 50-358 August 8, 1980 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: D. G. Eisenhut, Director Division of Licensing Re: WM. H. ZIMMER NUCLEAR POWER STATION- - ~ ~ ~

UNIT 1 - CITY OF MENTOR'S OBJECTIONS TO COMPANY'S EVACUATION TIME ESTIMATES Gentlemen:

On August 1, 1980, Cincinnati Gas and Electric Company submitted evacuation time estimates for the Zimmer Nuclear Power Station to the fluclear Regulatory Commission. Part of the study was performed by the Kentucky Division of Emergency Services, and the following remarks apply to that part.

hentor is the city in Kentucky nearest to the Zimmer fluclear Pow-er Station and has a strong interest in the development of sound emer-gency response plans. It has demonstrated its concern by becoming a party in the licensing procedure of the Atomic Safety and Licensing Board. Mentor takes issue with the study and advises this office that the city does not concur with it.

Mentor was not advised that the study was contemplated or that it was being prepared, was not consulted during its preparation, did not participate actively or passively in its preparation, and was not informed of its completion or that it had been transmitted to the com-pany. Mentor has had no opportunity to inspect, modify, or approve the study or any part of it either before or after it was presented to the company.

This study does not respond, or responds inappropriately or in-completely, to several elements in NUREG - 0654 (see especially II-J-8; II-J-10a, b, g, i, k, 1; and Appendix 4). Since NUREG - 0654 (part I-C) states that NRC regards "all of the elements contained here as essential for an adequate radiological emergency plan" (emphasis added), the study must be reviewed with its completeness according to the standards and criteria of NUREG - 0654 foremost in mind.

Among other deficiencies, the study is deficient in that it hO .5

--does not provide evacuation time estimates for the 2 miles and 5 miles distances. /

ADO.' u6 h, 0!*Gh I O 8 0080150

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To: U.S. Nuclear Regulatory Cornission August 8, 1930 Re: WM. H. ZD7ER NUCLEAR POWER STATION- Page

• 2 UNIT 1 - CITY OF MENTCR'S 03JECTIONS TO CO'>PANY'S EVACUATION TIME ESTIMATES

--does not provide evacuation time estimates by sectcrs.

--does not contain population figures.

--does not contain road traffic capacities.

--includes estimates for only one of the several scecial facilities and probler.-situations within the EPZ.

--is so rudimentary in its statement on methodology that neither the methodology nor the relationships of the con-clusions to a methocology can be evaluated.

--does not provide alternate evacuation routes or for traffic flow in the opposite direction on the provided routes in consideration of different plume directions.

--dces not rention a serious road hazard that presently exists on an evacuation route (deterioration of KY. Rcute 3).

This study does not reflect the guidance of NUREG - Ct'.4 and has not had the benefits of the unique insights, knowledge of the area, and

. experiences of the City of Menter.

Respectfully,

,,, L y l:)s <r

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v Mary Reder Representative of the City of Menter cc: Charles Sechhoefer Glenn O. Bright Frank G. Hoccer Troy 3. Conner, Jr.

Charles A. Barth ASL3 Panel Michael C. Farrar NRC Occketing L Service Section William J. voran W. Peter Heile Leah S. Kosik John 3. Acliver David K. Martin Robert A. Jones Andrew 3. Dennisen Dale D. 3redkey

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