ML20039G247

Direct Testimony of E Erbe Addressing ZAC-ZACK Contentions 20x,20(b),20(c),20(e),20(f) & 20(g).Related Correspondence

ML20039G247
Person / Time
Site:	Zimmer
Issue date:	01/06/1982
From:	Erbe M ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY
To:
References
ISSUANCES-OL, NUDOCS 8201150418
Download: ML20039G247 (8)

Text

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UNITED STATES OF AMERICA

'82 JV! 12 P3:27 NUCLEAR REGULATORY COMMISSION v

ATOMIC SAFETY AND LICENSING BOARD E -

f In the Matter of  : Docket No. 50-358-OL .

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THE CINCINNATI CAS & ELECTRIC  : APPLICATION FOR AN (

COMPANY, et al.  : OPERATING LICENSE, , i

. REcgfVED l 9- \.\ ;

(Wm. H. Zimmer Nuclear Power St at ion ~)

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E g%Ky DIRECT TESTIMONY OF EUGENE ERBE ADDRESSING THE ZIMMER AREA q / '

CITIZENS-ZIMMER AREA CITIZENS OF KENTUCKY CONTENTIONS 20X, w to 20(b), 20(c), 20(e), 20(f) and 20(g)

State of Ohio )

) SS:

County o.f Clermont)

Eugene Erbe, being duly cautioned and sworn, states the following for his I testimony. I, Eugene Erbe, reside with my wife and children at 3146 State Route 222, Bethel, Ohio. For approximately the past ten years I have lived within a

! ten mile radius of the Zimmer Power Station site in Clermont County. For

^

- approximately eight. of those ten years, I have lived in Moscow, Ohio, within 1/2 mile of the Zimmer site. I am employed as a teacher in the Cincinnati Public School System and have been employed by the Cincinnat' Public School System for the past nine years. I received a masters degree in Education from Xavier Univers it y. Both in my college and graduate education, I have received training i6 establishing, administering, and interpretting surveys. Between 1972 and .

1974, I was v' ice president of the Moscow Life Squad. I have worked over the Q

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8201150418 920106 l PDR ADOCK 05000358 '

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past years with local police in the Moscow, Ohio, area on a volunteer basis. I have also worked with the Moscow Elementary School P.T. A. on a volunteer basis.

Over the past - ten years I have traveled every or almost every road in Clermont County, and am particularly knowledgeable about the roads in southern Clermont County.

In the fall of 1981, I developed and administere'd a survey of various roads s which are within a ten mile radius of the Zimmer Power Station (EPZ) in Clermont County. In conducting this road survey, I trained approximately twenty volun-teers who were assigned various roadways to er. amine noting certain characteris-tics such as: the width, the existence and size of berms, the topography, the condition of the road surface, the location of residences, int ersec.t ions , and the number of curves. A copy of the form that each volunteer was given is attached as Exhibit 1. At tached as Exhibit 2 is a map of Clermont County indicating the roads which were surveyed. Af ter the volunteers were trained by me and conducted the survey, I examined the results by personally checking and performing the same measurements on various of the roads surveyed and comparing measurements derived from the survey with maps and measurements developed by Clermont County, Oh io. I found the results of the survey to be less than a 10% ~

variance from my own examination of the roads and information derived from official Clermont County maps of the same roads. My testimony which follows is based in part upon this road survey I conducted and primarily upon my personal knowledge of roads in Clermont County, Ohio.

I. Contention 20X U.S. 52 travels basically east-west through Clermont County entering Hamilton County on the west side and Brown County on the east side. All roads 8

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heading in a north-south direction which are evacuation routes (in the event of an emergency at Zimmer) contain s:$sral hills. U.S. 52 is comparatively: (1) st raight ; (2) level

• and (3) free from unreasonable obstructions. U.S. 52 cont inues in Brown County in the same condition as described above.

If residents in the western part of Brown County had to evacuate, they ,

could proceed east on U.S. 52; o'r in a northerly direction on S.R. 505 inter-secting with S.R. 756 near Feesburg; or in a northerly direction on S.R. 221 intersect ing with S.R. 125 at Georgetown; or in a northerly direction on U.S. 68 at Ripley approximately 30 miles from'Zimmer. S.R.505 ands.R.h21are.often steep, winding, rough and narrow. There is a marked lack of berm and guardrail conditions along these roads. These roads become generally. impassable in snow and ice. S.R. 221 is additionally subject to flash flooding as it follows White Oak Creek. .

II. ' Content ion 20(b)

During 1972, 1973 and 1974 I personally observed that there is limited radio communication due to natural obstructions in southern Clermont County which~ include: (1) no contact from a mobile unit between Point Pleasant and Clermontville to a base in New Richmond or to other mobile units in New Richmond

^

'or Moscow; '(2) limited contact from the base radio to suppressed areas around .

Moscow which lie below the crest of the hill leaving the river basin and limited or'no contact between mobile units in that area. I also observed that 'here t

were radio communication problems between various departments such as the County Sheriff's. Office and affiliated agencies. Also unreliable communication by radio are oft'en caused by the weather conditions. .

III. Conten' tion 20(c)

Generally the evacuation roads in Clermont County will not support a heavy traf fic' flow which would be necessary in the event of an emergency at Zimmer

necessitating evacuation of the general puLlic. Many of the rosds contain disabled vehicles could be removed from the insufficient berm conditions so that roadway.

There is insuf ficient manpower in law enforcement personnel to control conditions within the EPZ. There would be insuf ficent services to aid d vehicles so that they might continue or evacuate persons froe disabled vehicles There would be two-way or assist.and evacuate vict ims in auto accidents.

l traffic on two lane roads resulting possibly from neighbors traveling to he p .

each other or of f-site vehicles returning to evacuate family members in the EPZ.

Traf fic control at many intersections is ILnited and hazardous due to topography and visibility conditions. In the event of inclement weather many roads would be impassable due to topographical conditions, improper or lack of road treatment ,

Heavy rainfall creates

) improperly equipped vehicles and driver limitations.

of heavy runoffs which cause flash flooding and

' abnormal hazards as a result Fog hilly areas and inadequate drainage causing floodwaters over roadways.

or near conditions, which are very common to many areas in Clermont County at king of the Ohio River, creates severe driving conditions due to the poor mar number of roadways to evacuate the roadways. Finally., there are an insuf ficient population. -

I The school buses and the CART buses designated as evacuation vehicles will I

l to weight limitations on l be unable to travel some township roads due in part some bridges. Because of the size of these vehicles, they will be unable to i In addition, CART and school buses would be I turn around at certain residences.

totally useless in obtaining access to certain residences during , heavy rain where In many locations in the EPZ in Clermont creek beds become part of driveways.

!- County, there are narrow or single lane bridges which will create tra'f fic i

problems during evacuation as larger buses will be driven into the EPZ in the Disabled and other special direction opposite of the general evacuation flow.

care evacuees will necessarily slow the progress of the evacuation process and 1(pit the number of persons which each evacuation bus may contain.

The road survey I conducted describad cbove exr;minad the distences frer, Hom,e s built within the past roadways of all residences older than six years.

surveyed or distanced six years, which comprised 13% of all residences, were not from the roadway. The remaining 87% of residences contained the following

' distances from roadways: 49% are within 50 feet of the roadway; an additional of of the roadway; an additionall1% are within 200 feet.

19% are within 100 feet from the roadway.

the roadway; and an additional 8% are over 200 feet IV. Contention 20(e) 1 Zimmer necessitat ing public' evacuation, In the event of an emergency at the evacuat' ion could occur in a there will be no reasonable assurance that 1

f many timely fashion due to the general road conditions and the distances o It is also likely that many key volunteer personnel

, residences from roadways. -

of the EPZ.

would be unavailable to respond immediately due to being at work out evacuate their Furthermore, it is likely that volunteer personnel would first Further,-

' own families rather than assuming their assigned roles immediately.

' personnel would be insufficient due more, the response of local law enforcement i delay in to:

the limited training that many such personnel possess; the t me l- danger of a obtaining the maximum of personnel to respond to emergency; and the general breakdown of law and order due to panic caused by an emergency.

V. Contention 20(f)_

of even limited flooding by the Ohio River, many roadways in As a result The precise locations of roadways Clermont County in the EPZ are impassable.

i rendered impassable in t imes of flooding can be easily ascertainable by exam na- .

County. In the past when roadways have tion of topographical map of Clermont 4

been flooded, there has been severe overloading of traffic on secondary roads.

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VI. Contentions 20(g)

Periods of heavy snowfall and ice in the past have rendered all roads i including U.S. 52 immediately surrounding the Zimmer site to be impassable. Due

. to the lack of snow removal equipment in southern Clermont County many roads in the past have remained impassable for long periods of time in the winter.

- 2 fugerd Erbe' ' ~

Subscribed by in my presence and sworn to me this I day of January, 1982.

)'/G/ sw ary Public I: :. .

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