ML20039B567

Requests for Admissions by Commonwealth of Ky

ML20039B567
Person / Time
Site:	Zimmer
Issue date:	12/21/1981
From:	Dennison A ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY
To:	KENTUCKY, COMMONWEALTH OF
References
ISSUANCES-OL, NUDOCS 8112230241
Download: ML20039B567 (7)

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DOLKETED U9!?.C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '81 EC 21 A10:50 ATOMIC SAFETY AND LICENSING BOARD

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& SERVICE

• '!;CH In the Matter of  :

Docket No. 50-358-OL THE CINCINNATI GAS & ELECTRIC  :

COMPANY, et al.  :

' APPLICATION FOR OPERATING (Wm. H. Zimmer Nuclear Power  : LICENSE g p Station)  :

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REC 2ttign~ {9 INTERVENOR ZIMMER AREA CITIZENS-ZIMMER AREA CITIZE! C4 .

Ob 0F KENTUCKY REQUESTS FOR ADMISSIONS BY STATE OF KE DQKY % di 4 __

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9 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.-

52.742 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 the time stated.

1. Potassium iodide is a blocking agent of the thyroid gland to reduce absorption of radioactive materials.

2. Potassium iodide, if administered within two hours of exposure to radioactive materials, will substantially reduce in-take by the thyroid gland of such materials. g3 1[(

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3. Administration of potassium iodide two or' more hours after exposure to radioactive materials is 50 per cent e f fect ive.

4. Children under the age of 13 years, pre puberty, are susceptible to acceptance and retention of radioactive materials by the thyroid gland.

5. Monitoring of evacuees at reception sites, or centers, is to'be

^ accomplished within twelve hours of the evacuee's arrival at such site.

6. 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.

7. The Superintendent for the Campbell County Schools has four trunk . lines for in-coming and out going telephone calls to the schools within Campbell County, Kentucky.

8. Five elementary and one middle school in Campbell County, Kentucky are serviced by one trunk line for in-coming and out going telephone calls to such

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9. - The bus garage servicing school buses for student use for all students located in school situated in Campbell County, Kentucky, is serviced by two -

trunk lines for in-coming and out going telephone calls.

10. There are no dedicated telephone lines existing and^ servicing'any:

school, superintendent or para-school personnel in Campbell-County, Kentucky.

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11. No Campbell County, Kentucky school, .its superintendent or para-school' pcrsonnel have two-way radio communications between themselves, ' bus drivers, buses, orL the Campbell County EOC'or the EOF.

12. There are nine schools situated in Campbell County, Kentucky and which are !!ocated 'within the plume -exposure pathway of that emergency planning zone.

13. There are 6,111' students enrolled in the Campbell County,' Kentucky schools located within the plume exposure pathway of the ' emergency planning zone.

14. There are 60 buses possessed by the Campbell County School District for.

the . evacuation of the students present in the schools located within the plume exposure _ pathway of th_e emergency planning zone.

.15. The handicapped ' students enrolled within the Campbell County, Kentucky schools are required to be bused by lift -buses, of which there are two, and to timely and safely evacuate all handicapped children within the Campbell schhols it is necessary that 'four lift buses be present.

16. The school buses used for the. transportation of students within the plume exposure pathway of the emergency planning zone in Campbell County, Kentucky are within the control of the buse drivers during the course of the school day and.are not parked at the school site.

17. With respect - to the Campbell County Radiological Emergency Response l Plan (hereinafter the Campbell Plan), the following are true facts concerning the evacuation routes:

4 (a) evacuation routes 1121, California Cross Road, and

. Persimmon Road Pike are narrown winding, and hilly with steep inclines in parts; (b) Lickert Road has four 90 degree turns and a narrow bridge impending evacuation and, where it intersects with U.S. 27, there is no access point contrul to direct traffic flow; (c) Ky 8 is narrow without road berm or shoulder, an approxi-mately one-half mile southeast of Oneonta for approximate -

distance of one-fourth of a mile the road has eroded and been without repair for a substantial period; (d) Wesley Chapel Road and 1197 are narrow, and hilly ridge roads in many parts; (e) Ky 10 is a narrow winding ridge road in many parts and parallels Twelve-Mile Creek, and during flooding, this portion of Ky 10 is often impassabla;' and (f) there are approximately 50 rural service roads that the population must travel to evacuation roads which are approxi-mately twelve-feet wide or less in many parts and often are gravel roadways.

18. With respect to the Campbell Plai, the evacuation time estimates for the evacuation of the Campbell population, which range from 1.0 to 2.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, was calculated based upon optimal conditions which would not include:

(a) that portion of the population which may have inadequate fuel in an evacuation vehicle; (b) those persons in the evacuation area in a single vehicle

family in which the vehicle is away from the home; (c) times of inclement weather including snow, ice, and flooding.

(d) road intersections; (e) roads less thant 12 feet in width (f) roads without berm or shoulder; l (g) roadway blockage due to vehicular mishap.

19. With respect to the Pendleton County evacuation routes described in the

' Pendleton County Radiological Emergency Response Plan (hereinafter the Pendleton Plar), the evacuation routes for the population include the following:

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(a) Corntown Road, Ky 10, Flour Creek Road, 159, Concord Caddo Road and Falmouth Lenexburg Road are all in many parts ridge roads, steep, narrow, and winding and in areas limited to maximum speeds of 25 mph; (b) the approximate 20 rural service roads that the popula-tion must travel to evacuation roads are in many parts a maximum of 12 feet wide without center lines and in.many cases gravel roads.

20. The evacuation time estimates in the Pendleton Plan were calculated' based upon conditions which would not include:

(a) those portions of the population that do not have ade-quate fuel in their evacuation vehicic; .

t (b) those members 'of single vehicle families in the evacua-tion area whose family vehicle. is away; (c) t imes during inclement weather including snow, ice, and floods; (d) times when the roads are rendered impassable due to accident or mishap.

(e) road intersections; i

(f) roads less than 12 feet in width (g) roads without berm or shoulder.

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21. With respect to the Bracken County. Radiological Emergency Response Plan (hereinafter the Bracken Plan), the evacuation routes include the following:

(a) Ky 10, 1109, and Ky 8, all of which are in many parts ridge - roads , steep, hilly, narrow, and winding.

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22. The approximate ten rural service roads which residents in Bracken County'must travel to evacuation routes are in many parts no greater than 12 feet in width without center lines, winding and hilly and often gravel covered.

23. The evacuation time estimates in the Bracken Plan were calculated based-upon conditions which would not include:

(a) Those portions of the population that do not have ade-quate fuel in their evacuation vehcile; (b) Those members of single vehcile families in the evacua-tion area whose family vehicle is away; (c) Times during inclement weather including snow, ice, and -

floods;

'(d)- Times when the roads are rendered impassablh due to accident or mishap.

24. All the fire departments in Pendleton County are staffed by volunteers.

25. All contact with Pendleton County fire units is by telephone.

26. Pendleton County has no rescue squads except those present in the volunteer fire departments.

27. All of the four fire departments in Bracken County are staffed by volunteers who are trained at fire and rescue only.

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28. With. respect to the various state and county radiological emergency plans, in the event an evacuation of areas surrounding the Zimmer Station is necessary, :he 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.

t Al@REW 15. DENNEON 200 Main Street Batavia, Ohio 45103 (513) 732-6800 Attorney for Intervenor ZAC-ZACK t

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