ML20039B523

Requests for Admissions Directed to Clermont County,Oh

ML20039B523
Person / Time
Site:	Zimmer
Issue date:	12/21/1981
From:	Dennison A DENNISON, A.B., ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY
To:	CLERMONT COUNTY, OH
References
ISSUANCES-OL, NUDOCS 8112230190
Download: ML20039B523 (11)

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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

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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

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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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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.

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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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