ML20039G034

Direct Testimony of G Sell,M Reinhardt & W Voelker Addressing ZAC-ZACK & City of Mentor Contentions Re Campbell County School District Contentions.Related Correspendence

ML20039G034
Person / Time
Site:	Zimmer
Issue date:	01/04/1982
From:	Reinhardt M, Sell G, Voelker W ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY
To:
References
NUDOCS 8201150197
Download: ML20039G034 (9)

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UNITED STATES OF AMERICA COME Er

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NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

'82 JN! 12 P3:26 h

In the Matter of  :  ;

CINCINNATI GAS & ELECTRIC  : DOCKET NO. 50-358 COMPANY, et al.  :

(William H. Zimmer Nuclear  :

Power Station)  : APPLICATION FOR AN OPERATING LICENSE DIRECT TESTIMONY OF GENE SELL, MYRON REINHARDT AND WILLIAM VOELKER, A PANEL OF WITNESSES, ADDRESSING THE ZIMMER AREA CITIZENS-ZIMMER AREA CITIZENS OF KENTUCKY AND CITY OF MENTOR CONTENTIONS PERTAINING TO THE CAMPBELL COUNTY SCHOOL DISTRICT SET FORTH BY CONTENTIONS 20, 20b (6) , (i) , (ii) , (iii) , (iv) ; 21 )

(2); 21c(4); 21d, 21d (1) , ( 2 ) , ( 3) , ( 4 ) ; 21e, 21 , , 4 (2) , (3) ; 36 (E) .

MECE0VED \\

State of Kentucky ) j JAN1'31982"* I2

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County of Campbell ) 9 "**lgema n

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Gene Sell, Myron Reinhardt and William Voelker, b G3 0) cautioned and sworn, as their testimony ~ state as follows.

I, Gene Sell, am the Superintendent of the Campbell County School District and my business office is 101 Orchard, Alexandria, Kentucky.

As the Superintendent of the Campbell County School District, I am responsible for the health and safety of the students enrolled in the public schools of my district at all times that the students are within the control of the district, which includes presehce at public school sites, during school programs conducted away from the school site and during school bus transportation of students. I am ,

further responsible for the health and safety of the students enrolled in the private schools of my district at times that such students are being transported by school bus and I am obligated to ensure safe transportation of such privately enrolled school children and T

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to provide school bus-transportation for students enrolled in private 4

schools within Campbell County, Kentucky. I am responsible for the administration of all affairs present and touching upon the public schools within the Campbell County School District, and to provide-the programs required by law for the benefit of pupils and to take measures necessary for the well-being and protection of school children entrusted to my care in the Campbell County School District.

I, Myron Reinhardt, am the Deputy Superintendent and Director of Transportation for the Campbell County School District and my business office is 101 Orchard, Alexandria, Kentucky. It is my responsibility to assist-Gene Sell in the administration of his-duties as Superin-tendent and I have the direct responsibility for the direction, l operation, control, routing and other matters pertaining to the transportation of both public and private students enrolled in the -

schools'within the Campbell County School District. Included within my duties is the responsibility to provide safe transportation for 1

all students enrolled in the schools within the Campbell County School District and to protect the health and. safety of school children. -

I, William Voelker, am the Principal of A. J. Jolly Elementary.

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f School, a public school of the Campbell County School District and located at Route 2, California, Kentucky. My business address'is 101 Orchard, Alexandria, Kentucky. As the Principal of A. J. Jolly l

Elementary School, I am responsible for the health and safety of the pupils attending this school during their presence at the school

site and for their transportation to and from that school site to the point and place where the students are released to the care and control of a parent, guardian or other proper custodian.

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  Z for the second shift, the parent being responsible for transporting a

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the student at the mid-day shif t change. Once the buses commence their routes there is no meant of communicating with the driver and'the drivers are not available during the course of the day b tween routes for communications unless reached by telephone and l'

if the driver is present at the site of that phone. In the event

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- that it is necessary to summons buses to schools for evacuation r'5

, during the course of the school day it is difficult and time consum-r '

-ing to summons the drivers and there is no reasonable assurance that drivers can be contacted to respond to such an emergency.

Snow and ice accumulation and flooding circumstances present a

/ I difficult situation with which to effectively transport school e children'by school bus. During December, 1981, the schools of

> , 371 this District were closed due to roadway conditions of snow accumu-7

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laticn for a period of four days: consecutive Thurs' day, Friday and

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following Monday and Tuesday. During the scholastic years 1976-1,977 and 1977-1978 the schools of this District were closed 23 and g5 dafa, respectively, due to impassable roadway conditions.

f" , In the past, and due to snow and ice accumulation and flooding 1  :

cpnditions,as well as vehicular accidents blocking roadways, school

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buses' have been unable to transport school children or were blocked during transportation due to traffic conges' tion. Portions of Route l' '

b 10 for an approximate distance of four miles, between Cartha~ge and

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, Chlifornis Cross Roads, are rendered impassable due to either flash

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,* m flo6 ping"dr flooding of the Ohio River and remain impassable for 7 several' days requiring alternate bus routing. Oneonta Road from

+ 3 Ro'nte 8.to Ecur and ,12 Mile Pike is rendered impassable for approx-imE sly',10 days each year due to flash flooding and the floodir,g of

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the b io River. U.S. 27 du ing snow and ice circumstances is closed fr8m A.lekandria to Cold Spri6gs.

.- Bus transportation is limited V '. r s-

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during i'nclement weather due t6 the nature of the roadways within the District: narrow, steep and winding roads, generally without t berms, and the' absence of adequate bus turn-arounds. These roadways

_ further creats the

• problem of s'tudent transportation, especially s._,

A. J. Jolly and St. Peter an'djPaul Elementary Schools, because of tra f fic congestion-due to vehicular accident or snow fall, and .in the event of resident evacuation the movement of school buses into and' from those two elementary schools would' be grea61y curtailed.

i ' Campbell# County School District has neither the funds nor the i

i buses and drivers to maintain' buses parked at the A. J. Jolly

! and St. Peter and Paul Elementary Schools to be available in the .

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event of-student evacuation. Buses would have to be dispatched from other sites to evacuate the students of those two schools and under the most optimum conditions to evacuate those schools it vould require two hours for evacuation, and under reasonably optimum i .

conditions three hours to facilitate evacuation of the students of '

h .A. J. Jolly and St. Peter and Paul. Under other conditions the -

minin us evacuation time for those scho.ols would be five hours to  ;

probably several hours after notification to evacuate.

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The' Superintendent's office has fo.ur service telephone lines, p the bus garage has two service telephone lines,. Campbell County High School has'three service telephone lines, Alexandria Elementary

:[ has two service telephone lines and the remaining schools have one service ' telephone line. During snow conditions and other similar e

circumstances the telephone lines servicing the schools, bus garage 4

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and Superintendent's Office are overloaded limiting and halting telephone communications. In the event of a declared emergency at the Zimmer Station telephone communications would be rendered useless due to overloading of the service lines by parent telephone calls and the total inability of the Superintendent to communicate with Principals, drivers, and othecs necessary during an emergency. Under the present conditions of relying upon telephones for communications and reception of radio transmissions, as well as television inform-ation, the Campbell County School District cannot timely and effectively communicate within its system or to summons and dispatch bus drivers to afford any evacuation of students to protect their health and safety. Evacuation of the students within the plume exposure pathway of the Zimmer Station would require at least several hours and would permit exposure of the children within the affected schools. The complexity of buses located at various sites during the course of the school day or in route, the communication with school bus drivers, the roadways involved, population reaction, school bus routes, and the other factors present, incidding the limited buses and telephone system, results in the inability of this District to effectively respond to timely and safely evacuate school children.

Two children attending the A.J. Jolly Elementary School, a school situated 3.5 miles from the Zimmer Station, have received maximum doses of radiation and this concern by the parents of those children has been expressed as to the timely evacuation of that school. Parents have generally evidenced anxiety as to the plans to be implemented for the protection of their children.

Meetings have been held between ourselves and emergency planners

e-and we have reviewed the Campbell County Radiological Emergency Plan ,

and the Protective Action Procedure plans in draf t form for schools j .-

in other counties and the A.J. Jolly Elementary School. Those plans are inadequate for us to engage in any emergency response i

for the protection of the children within our District. The plans to date are totally inadequate. We have been afforded 'little information. By way of example, the Protective Action Procedure plan for the response of "Take Shelter" provides that upon notif-ication~ teachers are to instruct the students to place cloth or paper over their mouth and nose, but without any consideration of the situation that would then and there exist as to the child's 4

anxiety or appropriate explanation and advice.

The county plan provides for the closing of school and discharging of students to their home upon the event of any accident at the Zimmer Station before an accident circumstance requiring "Take i Shelter" or " Evacuation." We cannot discharge our respo rsibility -

! to student and parent by transporting school children to a home which may be una'ttended and where the child may not be capable of entering upon the advice to do so and with the potential that the j . accident may accelerate.

We have not been advised of the hazards attended to a Zimmer Station

! accident, the times within which we must respond or other. matters i

critical to our planning and to-afford information to staff, including drivers, to obtain their assurance and agreement that they would provide emergency response support necessary to protect the children within this. school district. We have no means to obtain the support

.of parents and in the event of a Zimmer Station emergency parents would respond to the schools to transport their children and create

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traffic congestion at school sites frustrating any timely evacuation

of students by school bus.

In the event that an evacuation is declared during school when chil-dren are in route on buses there is no means available by which we could advise and alter busing and evacuate children present at schools, f . some portion of the student population being~at school sites and the other portion being on buses.

We do not have sufficient buses, drivers or communication systems ,

i 'to effectively implement protective action plans for the health and safety of school children within our District. We cannot implement the plans currently in existence to afford any protection of the students within this District and based upon the limitations

- heretofore addressed we must state that the Campbell County School District cannot respond to a Zimmer Station emergency in any degree which will protect the health and safety of our school children.

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GENE SELL orm AA Y

/g MYRON REINHARDT l

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WILLIAM VOELKER 5 worn to and subscribed in my presence this 4th day of January,

, . 1982. .

L l}6 I Notary Public

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