ML20039G212

Direct Testimony of G Sell & W Voelker Addressing City of Mentor Contention 84 Re Campell County School District. Related Correspondence

ML20039G212
Person / Time
Site:	Zimmer
Issue date:	01/05/1982
From:	Sell G, Voelker W MENTOR, KY
To:
References
NUDOCS 8201150388
Download: ML20039G212 (5)

Text

- --

~ u  : .. . . ....

~

UNITEliSTATESOFAMERICA MbNkN W ~^

s +

NUCLEAR REGULATORY COMMISSION '*.'

. . 9

. ::g .. ,

ATOMIC SAFTf AND LICENSING BOARD :j W. In the Matter of .-

[. q g ,

~

Uh' CINCINNATI CAS & ELECTRIC i COMPANY, et al. . .

- DOCIGPT No. 50-358 .

-.i.7

~

(WilliamH.Zh.merNuclear  : Zl Power Station)  : APPLICATION FOR AN OPERATINC LICENSE DIRECT TESTIMONY OF CENE SELL AND VILLIAM VO~ . NCTE it[

4 CITY 0? MENTOR'S CONTENTION 34 PERTAINING #.a.. CAMPBE NTY ' f.

. SCHOOL DISTRICT. -M

__gECCIyED ' 4  : .T$

,- 9' ~~

p, State of Kentucky '

'c Mp V4g D982m SS:

E= %

',, E

, , ' ' County of Campbell

{. .,

. Gene Sell ana William Voelker, beink first d ~

utione sworn, as ]

- La to ..:

their testimony state as follows. ,;

y.;

I, Gene Sell, am the Superintendent of the Campbell County. School District -

and my business office is 101 OrcMrd, Alexandrie , 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 incl.ide::, presence 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 transportated by school bus and I am ob- .

ligated to ensure safe transportation of such privately enrolled school chil'dren and to provide school bus transportation for students enrolled in privat'e schools

. within the Campbell County School Jistrict. I am responsible for the administra-tion of all affairs present and touching upon the public schools within the Camp- .

bell County School District and to provide the programs required by law for the benefit of pupils and to take reasures necessary for the well-being and pro-

,c tection of school children entrusted to my care who are within the Campbell County

- School District. (

ph ,,

8201150388 820105 5 4[f .

1

. PDR ADOCK 05000359

• T PDR ,

.i

l .

~

I, Willier. Voelktr, aa th2 Principal cf A. J. Jolly Elimintary Sch*.cl, c .

public school of the Campbell County School District and located at Route 2, 4

California,' Kentucky.. As the Principal of A. J. Jolly 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.

We incorporate by reference our testimony given addressing the contentions raised by Zimmer Area Citizens-Zimmer Area Citizens of Kentucky and further state as,follows. .-

The Campbell County plan contains the following statement: "During an emergency, Standard Operating Procedures (SOPS), developed from the plan, will be employed to respond to the emergency rather than this planning document".

This statement is essentially repeated in the Campbell County Basic Plan, Appendix ,

8, p..VII-8-1, and twice in the Kentucky plant Plan Organization, p. VI and Basic Plan, Appendix 5, p. 5 SOPS are not included in the plans and have not been sub-mitted separately. Since the plans disavow themselves and establish SOPS as the sine oua non of eme.rgency planning during an emergency, 'and since no SOPS.are con-tained in the proposed plans or have been otherwise submitted, the Campbell County

- School District does not have a plan to protect the health and safety of either the children or-the personnel it is responsible for, in the event of a radiologi. cal emergency at the Zimmer plant.

On September 29, 1981, a meeting was held to discuss the Zimmer Evacuation Plan. There were 33 people pres ant, including curselves. Among these were Greg Ficke of CG&E and Craig P.artin, Wayne Berry, and Bob Alexander of Kentucky and Campbell County D2S. That meetin6 was taped and a transcript of that meeting is attactied and incorporated into our testimony by reference. We certify that the transcript is a true and accurate representation of what was stated by all parties to the best of our reco11cetion and memory of that meeting. We were led to believe i

r . .

b'* '

by dG&E p;rscnn21 cnd Stata and County DES cfficials that many of our c:ne:rns

~

would be alleviated when Standard Operating Procedures were developed for the schools. Said SOPS would cover procedures for notifying bus drivers, communications amor4 school officials, a n d alternative _. routes of evacuation in the event of flooding or a charge of wind direction causing the plume pathway to shift, amorf other thirgs. The above list of concerns is not exhaustive and is given merely

~

to be illustrative.

Since September 29, 1981, one or both of us has attended four meetir4s dealing

, with the same concerns and topics. Those meetings took place on October 1, with the same pbdes being represented; October 12, with all parties except CG&E pre-sent; November 5, with CG&E and Kentucky DES being represented; and Decemhr 2, with only Stone and Webster and ourselves being present. .

At each meeting we were given the same assurances,i.e., that Standard Opera ^1r4 Procedures would be developed to deal with the problems that we have consistently raised and that our input and suggestions would be sought and welcomed. Further, we have been led to believe by Cincinnati Gas and Electric and Stone and Webster personnel that the Standard Operating Procedures for the Campbell County School District would be submitted to the superintendent for his tacit approval. To date we have not received written Standard Operatir4 Procedures for the Canpbell County School District, nor have we received satisfactory responses to the concerns raised in contentions 20, 20b(6), (1), (ii), (iii), (iv); 21, 21b(2); 21(c)(4); 21d, 21d(1),

(2), (3), (4); 21e, 21e(l), (2), (3) and 36(E), by Zimmer Area Citisens-Zimmer Area Citisens of Kentu'cky, er indeed the questions raised by us at the September 29th meeting.

We have reviewed a document purportir4 to be a draft of radiological emergency protective action procedures for A.J. Jolly Elementary School. This draft was sup-plied to us by counsel for the City of Mentor and was received by her in response to Interrogatory 118 propounded by ZAC-ZACK. A copy of that draft is also attached i

and incorporated by reference.

h

-l. .

....U

We have serious doubts as to whitha thic docu= nt is cf any h21p to us in i menting the Campbell County Radiological E=cr6ency Plan as it relates to The document does not address the problems that we have consistently]

district.

Specifically the draft does not address the problem of an overloaded tele The plan envisions telei. hone verification without any other two way co A.J. Jolly h system. The superintenienth office has afour line telephone system. f It has been our experience that when adverse weather c one line telephone system.

our phone system becomes overloaded due to the tions develop during achool hours There is no reason to think it would be arg number of parentscalling the schools.

nor is it realistic.in our view, to as; different during a radiolo6 cal 1 emergency

~

Without a that we could be notified withou[ notification of the general public.

two'-way co :unications system the Campbell County School District can its duty of protecting the health and safety of our school children or pe The procedures referred to above basically require the principal to When the buses arrive he is to see that ti listen to the radio for instructions.

The draft procedures do not at children are boarded and the bus-sent on its way.

contacted or what course of act the critical issues of how the busdrivers are the principal is to take if it appears that the buses will not arrive, eith to the school to traffic jans or accidents which are blocking the access route In short, the draft Standard Operating Procedures we have mechanical failures.

l do not address any of the concerns which we have raised in our testimony.

t

(

In addition, the Cacpbell County, School District intends to cc::ence sunne

' It is anticipated that the Campbell County HiSh School bui:

this coming summer.

h

- will be in contiruous use forthe duration of the summer and possibly other sc buildings as well. Transportation during the sun =er months is not provided' In the event of a radio 1'o61 cci amider

. by the Campb' ell County School District.

the summer months when school is in seccion, there are no plans or l

are aware of to direct school personnel action und.er these circumstances.

We are not convinced that the Canpbell County Radiological Ener6e l -

[

e ,

casibic of implementaticn as far as our echool district is concerned for tha simple r:ason that too many details necessary for implementation have not been given adequate thou6ht er consideration. The fact that Standard Operating Procedures are not yet in cxistence to deal with the various problems raised ih our testimony is indicative of this. We do not have a reasonable assurance that we would be able to protect the health and safety of our students, teachers or other personnel in the event of a radiological accident. The Campbc11 County School District has neithr the personnel, facilities, money or intention of developing Standard Operatin6 Procedures for its echools. It is our position that this Ier,ponsibility lies primarily with Cincinnati Gas and Electric and we feel that the applicant has not met the responsibility it has.

4 GENE SELL

// . N WILLIAM V0ELKER Sworn to and subscribed in my presence this 5th day of January,1982.

O h T/ h d ) fo' (be NOTARY PUBLIC ,

My com::Lission expires: 10/28/85 e

e o

-S-