ML20032B005
| ML20032B005 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 10/27/1981 |
| From: | Fisse L CLERMONT COUNTY, OH |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20032B006 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8111040266 | |
| Download: ML20032B005 (7) | |
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,6laln-00CMETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.
'81 OCT 30 P1:11 ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
OFRE OF SECRETARY John H. Frye, III, Chairman DOCKEI((fCi Dr. Frank F. Hooper Dr. M. Stanley Livingston In the Matter of CINCINNATI.. GAS & ELECTRIC COMPANY DocketNoQ fh h (William H. Zimmer Nuclear Power Station,
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INTERVEN0R'S MOTION TO SUBMIT SPECIFIC CONTENTIONS, ISSU1E OR SUBJECT MATTER (F PARTICIPATION
/f IntervenorClermontCounty, Ohio,herebymovestheBoardtoadmktte attached list of specific contentions on behalf of clermont County, Ohio, in the above-referenced matter.
The Board should note that negotiations and discussions towards satis-fying these contentions have occurred, and are in the process of continuing with regard to the satisfaction of the subject matter of the contentions submitted herein. The Board should further be advised that Intervenor Clermont County in-tends to make every possible effort in those continuing negotiations to satisfy the subject matter of these contentions as submitted.
A list of said contentions, and a memorandum in support of this motion, is attached hereto and designated Exhibit',s "A" and "B".
Respectfully submitted, g3 GEORGE E. PATTISON Clermont County Prosecuting Attorney f
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By: LAWRENCE R. FISS Assistant Prosecuting Attorney 8111 yDR 027 462 E. Main Street 0350 Batavia, Ohio 45103-2984 PDR (513) 732-7313
Exh bi/ M" DOCKETED UstlRC Whereas, C3Ermont County and Cincinnati Gas and Electric. Company, 11 00T 30 P1:11 (hereaf ter " applicant"), have been engaged in ongoing negotiations to provide and acquire equipment necessary for the applicant to satisfy all Fed u [ c[ETId[r
. m.v.i Regulations governing Emergency Respcase Plans, including but not limited to those aspects dealing with monitoring, notification, evacuation, assessment, training, and protective actions; and where as the applicant has provided and agreed to provide some items of equipment deemed necessary by Clermont County to perform its duties under those Plans for the assurance of adequate protection of the public and emergency response personnel; but that certain items of equipment and other procedures have not been provided or agreed to be provided by the applicant, and other matters concerning the maintenance, upkeep, replacement, supplementation, repair and training, as related to the Plan, equipment and personnel uccessary for the utilization of that plan, have not been resolved; and where as the County agrees to continue with negotiations to resolve those matters, but maintains that it is the applicant's primary responsibility to provide and assure the ability of the County to implement, utilize and maintain the Plan and components thereof, for the assurance of the adequate protection of the public and emergency response personnel, The County states the following as matters of contention and subjects upon which it intends to participate:
1.
Intervenor, Clermont County, while admittedly in possession of some communications equipment, does not have in its possession all communications equip-ment necessary for plan implementation, and/or notification, and/or evacuation, and/or communications with both residents and emergency response personnel in the emergency planning zones, in the event of an accident at Zimmer Nuclear Station, requiring such plan implementation, and/or notification, and/or evacuation, and/or communications;
2.
Clermont County does not have sufficient monetary capabilities or access to the required funds needed to acquire that equipment necessary for plan implementation, and/or notification, and/or evacuation, and/or communications with emergency response personnel and inhabitants of the emergency planning zones, where the situation is such requiring such plan implementation, and/or notification, and/or evacuation, and/or communication with said individuals; 3.
No arrangments have been entered into or binding agreements made to provide or furnish that equipment necessary for plan implementation, and/or notif:.-
cation, and/or evacuation, and/or communication with emergency response personnel and inhabitants of the emergency planning zones, where the situation is such re-quiring such plan implementation, and/or notification, and/or evacuation, and/or communication with said individuals; 4.
Clermont County, while admittedly in possession of some moni-toring equipment, does not have in its possession all monitoring equipment neces-sary for plan implementation, and/or notification, and/or evacuation, and/or com-munication with the emergency response personnel or inhabitants of the emergency planning zone, and necessary for post-accident functi'ons, in the event of an accident Zimmer Nuclear Station requiring such plan implementation, and/or notification, at and/or evecuation, and/or communication with said individuals and functions required by each; 5.
C1coront County does not have the monetary capability or access to the necessary funds to acquire said monito. ring equipment necessary for plan imple-mentation, and/or notification, and/or evacuation, and/or communication with the emerEency response personnel or inhabitants of the emergency planning zone, and necessary for post-accident functions, in the event of an accident at Zimmer Nuclear Station requiring such plan implementation, and/or notification, and/or evacuation, and/or communication with said individuals and functions required by each; kl ~
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No present arrangments have been made or binding agreements entered 6.
l into to provide or furnish the monitoring equipment necessary f or plan imp ementa-tion, and/or notification, and/or evacuation, and/or communication with the emer-gency response personnel or inhabitants of the emergency planning zone, and neces-at Zimmer Nuclear sary for post-accident functions, in the event of an accident Station requiring such plan implementation, and/or notification, and/or evacuation, and/or communication with said individuals and functions required by each; 7.
Clermont County does not have sufficient monetary capability, or access to the funds needed to maintain, service, replace, test, or acquire moni-toring or communications equipmcat; whether such equipment is notin their possession, a.
b.
whether such equipment is to be supplied, c.
whether such equipment is required under present rules and/or regulations, d.
or whether such equipment is to be required under subsequent rules and/or regulations, so as to be able to implement the plan, and/or notify, and/or evacuate, and/or communicate with the emergency response personnel or ' inhabitants of the emergency planning zone; 8.
Clermont County does not have sufficient monetary capabilities, or access to the necessary funds needed to acquire, maintain, service, replace, or test;
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any and all equipment,,,
a.
b.
acquire the expertise, personnel, or training necessary to implement and up-date the Clermont County Radiological Emergency Response P1 a(CCRERP), as required under Federal Rules and Regulations, or conduct the required exercises and/or drills under the CCRERP c.
as required under the Federal Rules and Regulations; 9.
Clermont County has not; received the necessary training, a.
s!'
- b..does'not possess the ability, expertise, personnel, or funds to provide the necessary training, and lacks the means of implementing procedures to provide c.
said training as required by Federal Rules and Regulations;
- 10. Clermont County does not have.the necessary. equipment to. provide for proper and appropriate independent assessment capabilities as required by Federal Rules and Regulations;
'll.
No binding arrangments or agreements to purchase the required equip--
ment to provide for proper and appropriate independent assessment capabilities-has
.been entered into between the parties as required by Federal Rules and Regulations; 12.
Clermont County does not possess sufficient financial capabilities,
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or have access to the necessary funds, to purchase that equipment needed to pro-t vide for proper and appropriate independent assessment capabilities, as required
-by Federal Rules and Regulations; AS A RESULT OF THE ABOVE LACK OF EQUIPMENT AND OTHER DEFICIENCIES, THE APPLICANT AND THE PLANS FOR EMERGENCY PREPAREDNESS AND EMERGENCY RESPONSE; A.
Fail to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emerr.ency to in--
sure adequate protection of public health and safety.
B.
Fail to provide or establish adequate procedure for' notification of f.'
local response organizations and for notification of emergency personnel.by all
'such organizations.
C.
Lack the means to provide early notification and clear instructions P
to the populace within the plume exposure pathway emergency planning zone..
Is not capable of being utilized to implement prompt communication-D.
r
.among principle response organizations to emergency personnel and the public L
J within-all emergency planning zones.
b i
-- - 2.
i E.
Fail to provide adequate emergency facilities and equipment to sup-port the emergency response, and/or the means and manner of maintaining them have not been provided or agreed upon.
to provide adequate methods, systems, and equipment for assessing F.
Fail and monitoring actual or potential off-site consequences of a radiological emergency condition.
Is not capable of being implemented to provide protective actions C.
for the plume exposure pathway emergency planning zone for emergency workers and the public.
Is not capable of being utilized to implement protective actions for H.
the ingestion exposure pathway emergency planning zone appropriate to the locale.
to provide the means for, and is not capable of being utilized 1.
Fail to provide the means for controlling radiological exposures, in an energency, for emergency workers.
to assure and cannot be implemented tc assure that periodic J.
Fail exercises will be conducted to evaluate major portions of emergency response cap-abilities, periodic drills cannot be conducted to develop and maintain key skills, deficiencies cannot be identified as a result of these exercises or drills so as to be corrected.
K.
Fail to provide for and is not capable of being implemented to pro-vide the necessary radiological emergency response training to those who may be called on to assist in an emergency.
to provide the proper :means and procedures.to assure adequate L.
Fail assessment of accidents and potential severity.
Is not capable of being utilized to implement adequate protective M.
actions in response to actual or anticipated conditions, and cannot be, and will not be taken.
b l
I N.
Is not capable of being implemented or intearated. into the 1
I applicant's plans.
All constituting significant deficiencies in the plan; adequate interim f
compensating actions hrve not, and cannot be taken.
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All in violation of 10 C.F.R. Section 50.34, 10 C.F.R. Section 50.47, and 10 C.F.R. Section 50 Appendix E.
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