ML19338C835

Comments on Util 800818 Preliminary Evacuation Time Study & Requests NRC Insure That City of Mentor Has Integral Role in Facility Emergency Planning.Study Has Serious Flaws That Must Be Examined & Corrected

ML19338C835
Person / Time
Site:	Zimmer
Issue date:	09/02/1980
From:	Reder M MENTOR, KY
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8009050333
Download: ML19338C835 (2)

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., t Docket No. 50-358 September 2, 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 COMMENTS ON CG&E'S " PRELIMINARY EVACUATION TIME STUDY..."

AND RELATED REQUESTS.

Gentlemen:

On August 18, 1980, the Cincinnati Gas and Electric Company sent you a " Preliminary Evacuation Time Study..." for its Zimmer nuclear power plant. Both the text and the cover letter qualify the study as prelimin-ary because of understandable factors. Nevertheless, along with the ob-vious errors of conclusion arising from internal inconsistencies, the study has a number of other serious flaws that must be examined at length and corrected before it can be seriously regarded as a basis for a com-prehensive evacuation time study. The company previously submitted to you other time studies to which the City of Mentor responded by listing several specific deficiencies and alluding to others. Mentor will not make a similar delineation for the present study now but is willing and ready to do so and offers its assistance to the NRC in evaluating this or any evacuation time study.

It is pointed out here that the City of Mentor is a governmental entity and, as such, has certain authorities under the laws of the Common-wealth of Kentucky, among which is the authority to protect the health and safety of its citizens. In addition, Mentor derives certain atten-tions, considerations and rights in the Zimmer matter from NUREG - 0654.

(See especially pp. 16-17.) Mentor has neither abrogated its authority nor delegated it tc any. county, state, or federal agency or to any elec-tric company. To this date, however, none of these has attempted to dis-cuss Mentor's Zimmer related requirements with Mentor and none has in-cluded Mentor in any discussion that any has had with another. Let it be known that there has been no ' mutual agreement" (NUREG - 0654, p.17) between Mentor and any other party on any part of any Zimmer emergency response plan. Mentor has not participated in any capacity in any plan-ning effort and therefore requests the NRC to fulfill the obligation to $O0f local governments it assumed in-NUREG - 0654 by taking steps to ensure 5 that Mentor has an integral role in the planning of Zimmer emergency /_

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e iw To: U.S. Nuclear Regulatory Commission September 2, 1980 Re: WM. H. ZIMMER NUCLEAR POWER STATION - Page # 2 UNIT 1 - CITY OF MENTOR'S COMMENTS ON l CG&E'S " PRELIMINARY EVACUATION TIME STUDY..."

l AND RELATED REQUESTS.

i The City of Mentor, as an " interested city" in the ASLB's Zimmer l proceedings, needs complete information at every stage in the develop-ment of all plans to protect the lives, health, ar.d safety of people who are unfortunate enough to live in the viciity of the Zimmer plant.

l The city further requests that the NRC provide the city with its evalua-l tions of this evacuation time study and all that have been previously l submitted and with the NRC's evaluations of all evacuation time studies and related planning efforts from time to time as they are completed.

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Respectfully, D d Mary Reder Representative of the City of Mentor cc: ASLB Panel Michael C. Farrar NRC Docketing & Service Section William J. Morgan W. Peter Heile Leah S. Kosik John D. Woliver David K. Martin Robert A. Jones Andrew B. Dennsion Dale D. Brodkey Charles Bechhoefer Glenn 0. Bright Frank G. Hooper Troy B. Conner, Jr.

Charles A. Barth i i

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