Text

Testimony of Applicants Re Emergency Planning Contentions. Prof Qualifications & Certificate of Svc Encl
	ML20040B126
Person / Time
Site:	Zimmer
Issue date:	01/15/1982
From:	; CINCINNATI GAS & ELECTRIC CO.
To:	;
References
	NUDOCS 8201250187
	Download: ML20040B126 (137)
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UNITED STATES OF AMERICA _

NUCLEAR REGULATORY COMMISSION 7 , r r, ?j o ' p q ? .s

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}\ n N s In the Matter of ) j

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The Cincinnati Gas & Electric ) !

l Company et al. ) Docke t No . 50-358

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l (Um. H. Zimmer Nuclear Power )

S tation )

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l APPLICANTS' TESTI MONY RELATING TO EMERGENCY PLANNING CONTENTIONS (

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r APPLICANTS' TESTIMONY REGARDING CONTENTION 20X Contention 20X. Authority for the requirement that Brown County, Ohio, be included into the emergency planning response of the plume exposure zone is as fo llows : Brown County is situated approximately 10 and 1/8th miles generally east from the Zimmer Station; the current plume exposure zone depicted on emergency planning zone maps presented in the local plans terminates the plume exposure EPZ at the Brown and Clermont Counties bo rde r ; the conditions of the topography and la nd characteristics placing the involved areas of Brown County in an elevation plane in excess of 400 feet above the Zimmer Station; access ro ut es for the af fected Brown County population a re in part common for certain affected population in Clermont County (particula rly U.S. 52 and the population of Clermont County involved in Designated Sector S E (G ) , ES E (F) and E(E) involving an approximate Clermont population of 2,518 (Clermont Plan, II-I, at pp. II-1-17 and II-I-22) in which that affected population is routed from U.S. 52 to S.R. 133 and subsequently alternate S.R. 222 and 232 (Clermont Plan II-I, at p.

II-I-18) requiring a greater distance and travel time within the plume -

exposed area); the condition that in Brown County there a re no response needs, capabilities or implementation of emergency resource personnel for an emergency response to a Zimmer accident or event; and 10 C.F.R. 50. 4 7 (c) ( 2 ) , wh ich provides, inter alia:

(g)enerally, the plume exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles (16 km) in radius **** The exact size and configuration of the EPZs surrounding a pa rticula r nuclea r power reactor shall be determined in relation to local emergency response needs and capabilities as they a re affected by such conditions as demography, topography, land characteristics, access ro ut es ,

and jurisdictional boundaries." (Emphasis supplied by writer.).

See also 10 C.F.R. 50. 3 3 (g ) to the same effect.

Testimony The boundaries of the Zimmer plume exposure planning zone were chosen by the involved state and local planners to be in accordance with the requirements of 10 C.F.R. 50.4 7 (c) (2) and the NUREC-0654 planning guidance. An examination of the demography, to pog raphy , land 1

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l characteristics and access routes concerning Brown County yielded no characteristics compelling an extension of the planning boundary 1

beyond a 10 mile radius in the direction towards Brown County.

i i Therefore, the edge of the plume EPZ was set at 10 miles which happened to approximately coincide with the Brown County border at one point. For the areas of Clermont County adjacent to Brown County and near the actual l'0-mile circle, the planners review of the jurisdictional boundaries resulted in the extension of the zone to include Bethel, Ohio, and areas of Clermont County south of route 125 f and east of Bethel, and make the actual Brown County boundary the edge of the pl ume EPZ although it is greater than 10 miles from the station. No further extension into Brown County was considered i

necessary based on jurisdictional boundaries.

Only 3587 people in Brown County live within 3 5 miles of

Zimmer. The population is la rgely in two small rural communities, _

with few others in tr. ) intervening countryside. There a re no large i

] communities near the edge of a 10 mile circle, nor is there any sudden change in the demographic cha racteristics of the area. If anything, i

j the population is generally less dense in the Brown County areas within 15 miles of Zimmer than is the case within 10 miles in i

southeastern Clermont County. The re are only two incorporated villages within 15 miles: Hammersville, Ohio (population 688) at i

about 13 miles, and Higgensport, Ohio (population 3a3) at about 15 miles. 'O the rw i s e , there are no concentrations of residences, and due ;

to the relatively rugged terrain, only sparse settlement elsewhere l 4

within 15 miles of Zimmer in Brown County. Therefore, there are no demographic features which would cause extension of the planning zone into Brown County.

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The topography of Brown County in areas ad jacent to Clermont County is very similar to that of Clermont. Plant grade at the Zimmer site on the Ohio River floodplain is 520 ft. MSL. On the Ohio side of the river, the terrain rises to an elevation of 800 to 900 ft. MSL within 1 to 3 miles of the river, and remains relatively level at

., greater distances. The upsloping terrain near the river is punctuated

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by a number of va11eys containing creeks which f'ow into the Ohio River. On the Kentucky side of the river, the terrain also rises to 800 to 900 ft. MSL within 1 to 3 miles of the river. The terrain within 15 miles of the plant may be characterized as hilly, with

elevations fluctuating irregularly between approximately 550 and 950 i

ft. MSL. Within the entire 15 mile radius into Brown County, the i

terrain is very similar to that of southeastern Clermont Co un ty ,

There a re no distinguishing features of the topography in Brown County as compared to southeastern Clermont County, therefore there are no speci fic topographic features of Brown County which would cause any _

, extension of the planning zone beyond ten miles. Further, there is no

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l topographic feature at or beyond a 10 mile radius of Zimmer in the 4

direction of Brown County which would significantly change the continuing dispersion of a release such as to require an extension of the Emergency Planning Zone beyond a 10 mile radius from Zimmer.

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Access routes out of a 10 mile radius from Zimmer in Clermont County are numerous and do not in themselves require the public to 1

l traverse through Brown County. Unusual geographic or road features are absent. There is no peninsula protruding into the area, there are no rivers to obstruct travel away from Zimmer in a generally radial ,

direction, nor are there any other unusual geographic-conditions restricting access routes. The mere fact that Clermont County residents from within the 10-mile circle may use roads in Brown County i

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or may use roadn enti rely within Clermont County, does not present an unusual access route situation that would requi re specific Brown County planning. The pa rt icula r route noted in the contention is simply one possible route out of an area of Clermont County and does not affect the choice of the planning zone boundary. The re fo re , there qf}

is no condition of access routes which would call for a zone other than the 10-mile radius.

It is noted that the selection of 10 miles was based upon typical 1000Mw(e) reactor. Therefore, inasmuch as Zimmer is approximately R40Mw(e), this selection is conservative.

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It is the re fo re concluded that the Brown County line is appropriate fo r the edge of the plume EPZ.

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APPLICANTS' TESTIMONY REGARDING CO NTENTION 20 b 4 Contention I

20 b4 Radio communications between base and mo bile radios utilized by Clermont County emergency response support groups within an approximate area of four miles of the Zimmer Station in the near environs of U.S. 52 pa ralleling the Ohio River of incapable of radio transmission due to topographical and land characteristics of that area creating blank, or void, rad io transmission whereby radio signals meet na tu ra l terrain ba rriers . (No plan provision) .

Testimony l

Presently there are radio propagation problems in the area of Zimmer Station due to the topography of the area. However, Applicants 1

are furnishing th ree (3 ) 100W radio base stations and antennas at its communications facilities located on a hilltop near Zimmer Station for County police, fire, and local government services and has also agreed to provide space at these facilities for a lifesquad radio system.

This will provide adequate communications in this area for the following agencies:

1. Clermont County Sheriff's Department

2. Monroe Township Fire

3. Monroe Township Police

4. Felicity - Franklin Fire Department

5. Felicity - Franklin Police Department

6. Clermont County Disaster Services Agency It will also improve communications for mutual aid purposes with the Moscow Lifesquad, Washington Township Fire Department, and 5

the New Richmond Fire Department. The Moscow Lifesquad and Washington Township Fire Depa rtment are dispatched by the New Richmond Po l i ce Department. They presently experience some transmission problems when their vehicles are in e vicinity of Neville and points further along the river. CG&E is working with New Richmond and Moscow officials to provide additional communications equipment which would improve communications in this area.

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r APPLICANTS' TESTIMONY REGARDING CONTENTION 20b5 :

, I Contention '

20b5. The Clermont County Emergency Plan provides for communications among some of its emergency resource agencies by non-dedicated telephone line only, involving limited trunk service to !

certain agencies (one to four telephone lines), utilization of long l distance telephone lines involving General Bell telephone systems, and ,

as such this portion of the communications plan does not provide a ;

reasonable assurance that communications necessary to a timely and l prompt evacuation can be implemented, especially where limited trunk l lines fo r telephone usage are subject to overload, e.g., :

t 20b51) Communications between the Superintendent of the I Clermont County Boa rd of Education-County EOC and the Superintendent [

of the Felicity-Franklin School District requires use of limited long !

distance trunk line, subject to overload, between Bell and General l Telephone Systems: Felicity Franklin Superintendent has three trunk j lines for use in communications between the County Superintendent and i i to summon school bus drivers (approximately 18) to the school site for i student evacuation; 20b5ii) The Superintendent of Bethel-Tate School District has t two telephone trunk lines, subject to overload, for use in [

communications between the County Superintendent and to summon school -!

bus drivers (approximately 15) to the school site for student !

evacuation; I

I 20b5111) The Superintendent of the New Richmond School District has four telephone trunk lines, subject to overload, for use [

in communications between the County Superintendent and to summon school bus drivers (approximately 17) to the school site for student evacuation and for telephone communica t ions to th e Mo n roe and Pierce Elementary Schools within the District, each school has two telephone i

trunk lines; i 20b51v) The telephone trunk lines for each of the affected school districts will be overloaded during emergency situations due to 1 parental telephoning into the schools; !

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20b5v) All notifications to the County Superintendent, !

affected school districts, reception school districts, school district ;

transportation supervisors, and school district bus drivers is by non-dedicated, existing telephone trunk lines. (Plan, II-E, Table E-1, '

) pp. II-E-3 and 5; III-A, p. III-A-2; III-C, pp. III-C-1 th rough 3d) .

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l The Clermont County Radiological Emergency Response Plan 4

(CCRERP) calls for use of commercial, non-dedicated telephone lines j for communications among school facilities. Advanced planning and alternate methods of communications assure an adequate capability to implement protective actions.

It is intended that initial notification of the County School

Superintendent and district superintendents take place prior to public

notification, and prior to the need to implement protective actions, I

t whenever possible. Incoming calls from parents, resulting in overloaded telephone lines, would not be of concern under such circumstances. District Superintendents are notified by va rious sources, have authority to implement protective actions for their

schools, and, therefore, are not dependent upon the County 1

j Superintendent for notification.

All schools located within the plume exposure pathway EPZ will be provided with institutional quality NOAA tone-alert radios as part l of the Prompt Notification System. In the event that initial i telephone notification is not made prior to public notification, t

school principals can be alerted via the NOAA tone-alert radios.

l Actions taken by the schools are independent si ~,hether notification 1

comes from thei r superintendent or by NOAA tone-alert radio.

i Bus drive rs will be notified by telephone, however, as with school principals, the prompt notification system (sirens and NOAA j radios) can be used to alert them to the situation, at which time they l

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(See also Testimony regarding Contention 20.e.l.)

Finally, volunteer amateur ra dio pe rs on nel are available to provide and operate amateur radios at schools, if necessary.

We maintal.n, therefore, that adequate primary and back-up communications exist to provide reasonable assurance that timely and Prompt implementation of protective actions, including evacuation, can be implemented, in the event of a r diological emergency at the Zimmer Station.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 20b6 Contention 20b6 The Campbell County Emergency Plan provides fo r communications among some of its emergency resource agencies by

monitor radio and non-dedicated telephone lines, involving limited j trunk service to certain agencies (one to four telephone lines),

subject to overload, and as such this portion of the communications plan does not provide a reasonable assurance that communications necessary to a timely and prompt evacuation can be implemented, e.g.,

t 20b61) Communications to County School Superintendent by monitor radio and subsequent non-dedicated telephone use (four trunk lines to Superintendent);

20b611) County Superintendent's notification to five elementary and one middle school, including A. J. Jolly Elementary School within two miles of the Zimmer Station, is by a single non-dedicated telephone line into each of the six schools, each trunk line into each school is subject to overload; 20b6111) The County Superintendent's notification to Alexandria Elementary School and the bus garage is by two non-dedicated telephone lines into each facility, both of which are .

subject to overload;

, 20b61v) The County Superintendent's fo ur non-dedicated trunk lines are the means of communications to 54 regular and seven i substitute bus drivers to summon school buses to nine school sites for student evacuation; 20b6v) The telephone trunk lines for each of the af fected schools, the Superintendent and the bus garage will be overloaded during emergency situations due to parental telephoning into the schools; 20b6vi) All notification (except initial notification to

Superintendent by monitor radio) and communications between schools, i

bus drivers and transportation supervisor is by non-dedicated,

, existing telephone trunk lines. (Plan, Basic Plan, pp. V-5,6; Annex l B, Communications, p. B- 3 ; Annex C, Notification & Warning, p. C-4.)

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Testimony I

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In Campbell County the primary means for communicating among !

the School Superintendent, schools located within the plume exposure

! EpZ, and the school's ga rage is by telephone. Advanced planning and

alternate means of communications assure an adequate capability to implement protect'ive actions.

It is intended that initial notification of the County School l Superintendent and schools located within the plume exposure EPZ take I

place prior to public notification, and prior to the need to implement j protective actions, whenever possible. Incoming calls from parents, i

resulting in overloaded telephone lines, would not be of concern under i

such circumstances.

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! Notification to the schools and the Superintendent's of fice is .

t not totally dependent on commercial telephone, as alleged in the above contention, but is backed by mo ni to r radios activated from the EOC.

Each school will also be equipped with an institutional quality NOAA

tone-alert radio as part of the Prompt Notification System. In

! addition, the following schools are located within siren range: <

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Alexandria Elementary School

} Campbell County High School St. Mary's Elementary School

! Bishop Brossart High School l

l A. J. Jolly Elementary School i

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In the event that initial telephone notification is not made prior to public notification, the Superintendent and the affected 1

! schools can be alerted via the NOAA tone-a lert ra di os . Actions taken by the schools a re independent of whether notification comes from their Superintendent or by NOAA tone-alert radio.

Bus drivers will be notified by telephone, however, as with school principals, the prompt notification svstem (sirens and NOAA rad ios) can be used to alert them to the situation, at which time they can proceed directly to schools fo r further instruction or action.

Finally, volunteer amateur radio personnel are available to provide and operate amateur radios at schools, if necessary. Further, radio communications could be established by dispatching a police car or other radio equipped vehicle to the school. We maintain, therefore, that adequate primary and backup communications exist to provide reasonable assurance that timely and prompt implementation of protective actions, including evacuation, can be implemented in the event of a radiological emergency at the Zimmer Station.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 20b7 ;

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Contention 20b7. The Pendleton County Emergency Plan provides for j notification and communications of and between emergency resource !

personnel by moni' tor radio and in most instances by pager or non-dedicated telephone absent reasonable assurance that contact can be {

made by pager (distance limitation in transmission) or by telephone, ;

} and as such this portion of the communications plan does not provide a ;

reasonable assurance that communications necessary to a timely and ;

prompt evacuation can be implemented, e.g., j 20b71) Judge / Executive notified from DES Director by pager or l

telephone; DES Director notified from Communications Coordinator by '

pager or telephone; County EOC personnel to be notified by telephone, pager, or radio; 1 #

20b711) DES Director contact, communication and notification i i with Fire and Rescue Coordinator by means of telephoning an answering ,

} service and thereafter the answering service " contacting" (a s sump t ion ;

j is by telephone) that coordinator who will in turn communicate with !

{ the DES Director P telephone; [

a e 20b7111) Communications to fire departments will be by telephone, whether between fire company members or between fire chief

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! and Fire and Rescue Coordinator (only the Falmouth Fi re Depa rtment has '

I radio contact with the EOC); y i !

20b71v) Notification to the Law Enforcement Coordinator from l

the DES Director by pager or telephone;

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r 20b7v) Notification to key emergency response personnel by I pager, telephone, or answering service, and communications with !

i certain emergency response personnel is inadequate to present }

l reasonable assurance that notification and subsequent communications i can be made and sustained where limited to non-dedicated commercial [

l telephone line providing for single telephone trunk. (Plan, Annex A, i Direction and Control, pp. A-5 through 7 and 9; Annex C, Notification ;

j & Warning, p. C-2-1). j 4

' i 20b7vi) Notification of special concerns by monitor radio (except Butler and Grant's Lick Nursing Homes and Black River Mining }

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Company which is silent as to notification) is Northern Elementary t School, other communications by commercial radio. (Plan, Annex F,

Protective Actions, pp. F-9-1 and 2).

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Notification of Emergency Response Personnel in Pendleton County is by pager, monitor radio, or telephone. It is intended that this notification would occur prior to public notification whenever possible. This system does provide a reasonable assurance that communications necessary to a timely and prompt evacuation can be implemented. It has been proven reliable in industry as well as in CG&E.

The special facilities in Pendleton County will be notified by telephone or monitor radio activated from the EOC and will also be equipped with NOAA weather radios as part of the Prompt Notification System. The Butler Nursing Home, Grants Lick Nursing Home, and Kincaid Lake State Park are within siren range. During its peak season, Kincaid Lake State Park will be equipped with a portable radio to maintain communications with the EOC.

Communications among response agencies will be maintained by l radio or pager. Communications with the fire departments is explained in Annex B of the Pendleton County Radiological Emergency Plan.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 20b8 Contention 20b8. The Bracken County Emergency Plan provides for notification and communications of and between emergency resource personnel by monitor . radio and in most instances by pager or non-dedicated telephone absent reasonable assurance that contact can be made by pager (distance limitation in transmission) or by telephone, and as such this portion of the communications plan does not provide a reasonable assurance that communications necessary to a timely and prompt avacuation can be implemented, e.g.,

20b81) Judge / Executive and DES Director notified from Communications and Warning Coordinator by pager or telephone; County EOC personnel to be notified by telephone, pager or radio; 20b811) Fire and policy emergency response personnel to be notified by pager; field fi re response personnel will communicate with the County EOC by telephone; 20b8111) Law Enfo rcement Coordinator will be notified by pager or telephone; 20 b81 v) Notification to key emergency response personnel by pager and communications by telephone; -

20b8v) Notification to School Preparedness Coordinator and to Western Hills Elementary School by monitor radio, other communications by telephone, including summoning of school buses for evacuation of students. (Plan, Annex A, Direction & Control, pp. A-6, 13, Annex C, Notification & Warning, C-2-1; Annex F, Protective Actions, pp. F-9-1 and 2).

Testimony The Bracken County Radiological Emergency Plan provides for notification by monitor radio, pager, and commercial telephone. This does provide a reasonable as su ra nce that communications necessary to a timely and prompt evacuation can be implemented. It has been proven reliable in industry as well as in CG&E. In the contention it states that Fire Departments will maintain communications with the FOC by telephone. However, some Fire Department vehicles in Bracken County are radio equipped.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 20 c 1 Contention.

20 c) The public roadways, as access roads for the evacuation of the EPZ populate of Clermont County, Ohio, and Campbell, Pendleton and Bracken Counties, Kentucky, are inadequate to promptly and timely evacuate the involved population.

Specifical ly, 20 c 1) The Clermont population is Designated Sectors SSE(H) and SE(G), a permanent population of approximately 800, proceed in an easterly direction from the Zimmer Station on the major evacuation route of U.S. 52, through Washington and into Franklin Townships to S.R. 133, the junction i of which is not an access control site and then proceed in a northerly direction !

on S.R.133, a distance in excess of 10 miles to S.R.125 at Bethel, Ohio, i at which point they are emerging from the plume exposure area (an approximate distance of 11-mile exposure of the plume on U.S. 52 and an approximate distance of 13-mile exposure of plume on S.R.133, for a total approximate distance of plume exposure of 24 miles): or alternatively the evacuees may proceed i northerly on S.R.133 to the Village of Felicity and then proceed on S.R.

4 222 to S.R. 232 to S.R.125 at Bethel (an approximate distance of ll-mile exposure of plume on U.S. 52 and an approximate distance of 20-mile plume exposure on S.R.s 133, 222 and 232, for a total approximate distance of plume -

exposure of 31 miles); or alternatively after trayeling on S.R. 222 to remain i on that route to its intersection with S.R. 125 near Bethel (for a total approximate distance of plume exposure of 29 miles). From entry onto S.R.s 133, 222 and 232 there are no control access control point until the evacuees ;

reach S.R. 125. At 0.25 miles east of the intersection of U.S. 52 and S.R. !

133, on U.S. 52, there is a manned access control to direct traffic flow .

return to S.R.133. The population east of the stated access control point '

(on U.S. 32 0.25 mile east of S.R.133) involving the populations situated east of S.R. 133 and the Village of Utopia and approximately 40 roads servicing i residents in the previously stated Designated Sectors and the additional Designated Sectors of E(E), ENE(D) and NE(C), are not within the eva, 'ation ;

route designated and must either proceed into the plume area by proceecing '

by roadways intersecting S.R. 133 or by following county and township roads !

to S.R.125 west of Bethel, or proceeding directly into Brown County. The i aforestated designated evacuation route fails in its implementation to timely i and promptly evacuate this portion of the Clermont population from the plume t exposure zone. (Clermont Plan, II-I, Protective Response, pp. 11-1-17, 18, i and 23). t i Testimony ;

., The Clermont County plan provides for the timely and prompt evacuation of the population of Clermont County.

The public will evacuate based on their knowledge of the local i road system and the intended destination, with the benefit of the evacuation i 16 .

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i i routes suggested in the " Circle of Safety" and the telephone directory. ,

Roads that may be used in an evacuation are roads in daily use by the populace. !

l This local road knowledge and suggested routes affords options as to specific i i

t.avel route.

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Evacuation is only one of the possible protective actions available l h

l to public officials for recommendation to the general public. Evacuation l' t

is recomended only when sufficient time is available to implement that alternative !

1 or, in the case where a release is in progress, when a significant savings [

f in exposure can be achieved. l l See also Testimony regarding Contention 20 c 6,10,12,14.

i The timeliness of an evacuation is measured only in comparison i to the available time in deciding protective actions. For example, if 8 l

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hours would be available prior to an expected release, and under existing !

weather conditions it is expected to take the affected area 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months to evacuate, [

then any evacuation under 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months would be " timely".

1 The establishment of access control points designated in the plans ;

is not intended as a prerequisite to proceed with an evacuation. Indeed, ,

t I an evacuation may be ordered before any access control points are established.

If established during an evacuation, access control serves to keep unauthorized i

i i persons outside of affected areas, and as a secondary benefit when possible, i, L

direct evacuees. Their primary function is controlling access into the affected i area.

l The Clermont County Sheriff, based on information from Zimmer and I

j the Clermont County Disaster Services Agency Director concerning direction l l

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of plume travel and affected sectors, and information from the County Engineer on weather and road conditions, may alter access control points from those designated in the plans to control access at different points, or to direct the flow of traffic to routes that will eliminate or minimize plume exposure.

(CCRERP, Section lI-I, page II-I-6, section /.)

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APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20 c 2 and 20 e 3 Contention 20 c) The public roadways, as access roads for the evacuation of the EPZ populate of Clermont County, Ohio, and Campbell, Pendleton and Bracken Counties, Kentucky, are inadequate to promptly and timely evacuate the involved population.

Specifically.

20 c 2) The Clermont population in Designated Sectors (portions)

E(E), ENE(D), NE(C), NNE(B) and N(A), constituting the populations of Monroe and Washington Townships, approximately 1,639 permanent population, are to proceed by alternative routes: one, a southerly direction to U.S. 52 toward the Zimmer Station and thence west on U.S. 52; two, proceed in a northwesterly direction to S.R.132, thence north on S.R.132 to S.R.125; or, three, a northeasterly direction to S.R. 222, thence northerly on S.R. 222 to S.R.

125; in which the roadways servicing that population for travel to an evacuation , ,

route consists of two state roadways and approximately 38 county and township roadways. Manned access control points are located on S.R. 756, 0.25 miles south of Brown Road, on Laurel-Point Isabel Road 0.1 miles west of S.R. 222, and on S.R. 743, 0.5 miles west of S.R. 222 in Washington Township to direct traffic flow, and at the junction of S.R.s 232 and 756, S.R. 232, 0.5 miles north of Ireton Trees Road and at the juncture of Franklin-Laurel and Carnes -

Roads in Monroe Township. The county, township and two state roadways for travel to an evacuation route situated in the aforestated sectors are narrow, r winding, hilly and hazardous roadways unsupervised for traffic flow and control, i except limitedly manned as noted, for prompt, safe and timely evacuation of the permanent population within the area. The road configurations will not afford directions by radio to that population of the numerous roadways >

that the population must follow to correct evacuation routes and.a safe evacuation in a prompt manner in the appropriate direction of travel cannot be implemented.

(Clermont Plan, II-I, Protective Responses, pp. II-I-17,18, 22 and 23.)

20 c 3) Clermont population in Designated Sectors N(A), NNW(R) and NNE(B), consisting of a portion of Monroe Township, Ohio Township and a portion of Pierce Township (a permanent population of 10,596), are to proceed l either to U.S. 52, thence in a westerly direction and out of the plume area; or, to proceed to S.R.132, thence in a northerly direction to 9.R.125, in which the roadways for travel to an evacuation route servitty that population consists of one state roadway and 27 county and township roadways, There are two access control points on the perimeter of the plume zone at the junction of S.R. 749 and Cole Road and on Jenny Lind Road, 0.25 miles south of Cole Road, but no access control points within the affected township areas. The roadways for travel to an evacuation route in the aforestated sector are narrow, winding, hilly and hazardous roadways unsupervised for traffic flow and control, except limitedly manned as noted, for prompt, safe and timely i evacuation of the permanent population within the area and a safe evacuation in a prompt manner in the appropriate direction of travel cannot be implemented.

(Clermont Plan, II-I, Protective Response p. II-I-17, 18, 22 and 23.) ,

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TESTIMONY ;

t The Clermont County plan provides for the timely, prompt and safe !

evacuation of the population of Clermont County, i The county, township and state roadways chosen for travel to an evacuation route are the roads that are used daily by the Clermont County ,

t population, and are therefore usable under these conditions. It is unreasonable l r

to assume that they would suddenly become unsafe during an emergency at ZPS-1. [

No directions by radio are necessarily provided during an emergency. !

! The actual routes selected by the public are based on their knowledge of !

the local road system and their intended destination with the benefit of 2

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i the suggested routes in the " Circle of Safety" and in telephone directory l 1

instructions. ;

i !

See also response to Contention 20 c 1. i

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J I

I 4 i h

i t 4 r i ?

i i

h 4

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I APPLICANTS' TESTIMONY REGARDING CONTENTION 20.c.5 Contention 20.c.5 The Clermont permanent population within the plume area is rural, generally serviced by narrow and winding township roads without center line and involving county lanes approximately eight feet in width and ranging from 200 to 700-foot depth from the township roadway. The use of CART buses, "as available", cannot reasonably assure prompt transportation for evacuees without vehicles assembled at pickup sites. School buses cannot l be used for public transportation; 3313.172 and 3327.14, Revised Code of Ohio, preclude use of school buses for public transportation, except transportation of senior citizens and adult education groups, rendering the use of school buses for public transportation unlawful. Vehicles used to afford transportation of handicapped and individuals without vehicles must be capable of driving i country lanes, removing the ability of buses, CART or otherwise, from traveling )

such lanes or negotiating turn-around at residences. The timely and safe i l evacuation of the population without vehicles cannot be implemented. (Clermont l Plan, II-I, Protective Response, p. II-I-5; III-A, County Agencies (Gen.),

pp. III-A-I and 2; III C, County School Districts, pp. III-C-I and 2).

Testimony The Clermont County Plan provides reasonable assurance that the handicapped and that portion of the population without personal means of transportation can be evacuated in case of an emergency.

l There is no basis for asserting that CART buses cannot negotiate all roadways in Clermont County. CART has 22 radio-equipped " buses" of various sizes of which some are equipped with wheelchair lifts. A majority of these buses,16 in all, are 12-passenger vans not much longer than a full sized station wagon and generally capable of traveling on any Clermont County roadway.

Of the larger buses, one has 32 seats and two have 36 seats. CART has 20 fulltime drivers, all with first-aid training.

2

'1

In addition to the portion of the general population that CART can evacuate, it is reasonable to anticipate that many people without personal means of transportation will arrange to ride with their friends, relatives, and neighbors who do have vehicles.

See also Testimony in response to Contentions 20.c.9, 24.10 and 36G.

22

t APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20 c 5 and 20 e 6 ;

20 c 5]. The Clermont permanent population with the plume

area is rural, generally serviced by narrow and winding township roads without center line and involving country lanes approxi-mately eight feet in width and ranging from 200 to 700-foot

depth from the township roadway. The use of CART buses, "as j available", cannot reasonably assure prompt transportation for ;

I evacuees without vehicles assembled at pickup sites. School ;

buses cannot be used for public transportation; SS3313.17 2 and

[

3327.14, Revised Code of Ohio, preclude use of school buses for t public transportation, except transportation of senior citizens r and adult education groups, rendering the use of school buses !

l for public transportation unlawful . Vehicles used to af ford :

transportation of handicapped and individuals without vehicles ;

, must be capable of driving country lanes, removing the ability y of buses, CART or otherwise, from traveling such lanes or nego- t tiating turnaround at residences. The timely and saf e evacua- .

tion of the population without vehicles cannot be implemented. [

(Clermont Plan , SII.1, Protective Response , p. II-I-5; SIII-A, ;

County Agencies (Gen) , pp. III-A-1 and 2; SIII-C, County School l Districts , pp. III-C-1 and 2]. ,

t f

20 e 6]. The Clermont County Sheriff is assigned the ->

primary command authority of all county activities in response ;

l to an emergency, including evacuation, and shall direct all !

primary and support agencies. The Sheriff shall direct all !

4 personnel involved in acess control, including local police, [

local fire and State Patrol. A county sheriff is empowered, and t i thereby limited, by S311.07, Revised Code of Ohio, to call upon i i

the sherif f of any adjoining county and municipal and township l officia'1s in his or adjoining counties, to furnish law ,

enforcement and fire protection, together with appropriate ;

equipment, as necessary, to preserve the public peace and ,

I protect persons and property only in the event of riot, !

insurrection, or invasion. The provisions of the plan providing ;

command authority for emergency response to a Zimmer Station event or accident is not within the provisions of S311.07 ( B) , 1

, Revised Code of Ohio, as the same does not consist of riot, f

insurrection, or invasion, and the plan as draf ted and to be ;

t implemented provides a power to the Sherif f of Clermont County j to control local police, fire and State Patrol contrary to the !

laws of the State of Ohio and the provisions of the plan are l unlawful. Based upon the legal status of the plan, it cannot ,

provide either reasonable assurance of implementation, or j implementation, by its assignment of command responsibility ;

contrary to state law. [Clermont Plan, SII-A, Command &

Coordination, p. II-A-1, Protective Response, p. II-I-6; SIII-A, County Agencies (Gen), p. III-A-12.] ;

I

Testimony Applicants submit that the Atomic Safety and Licensing Board is not the proper authority to determine the requirements

of state law, that function being left to the state courts. In Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2), ALAB-443, 6 NRC 741,748 (1977), the Atomic Safety and Licensing Board recognized that questions of Ohio law should be decided by the Ohio courts and that the NRC's

" job is to decide the federal issues before us." In Northern S tates Power Company (Tyrone Energy Park, Unit 1), ALAB-464, 7 NRC 372-375 (1978), the Appeal Board again stated that " [ t] he I

requirements of State law are beyond our ken." Thus, in the absence of a definitive ruling by an Ohio court of competent '

, , jurisdiction, the Licensing Board should not consider this matter. Intervenors should be left to their remedies under i

State law. If sometime in the future these matters are properly brought before an Ohio court which rules that the present plan provisions are not in accordance with laws, the matters could ,

j then be brought before the Nuclear Regulatory Commission.

l Moreover, testimony regarding the legal question is not proper. Certainly, if this is a matter which is to be decided by this Licensing Board under the Atomic Energy Act, adequate opportunity for briefs by the parties should be given.

However, Applicants do not believe that the Board need delve into matters of Ohio law raised by these two contentions.

Even assuming, arguendo, that the premise of Contention 20 e 6 ,

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8 Radiation:

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a The common denominator -

Sum of many parts Amencans keep dJving - to work, on errands. From cosmic rays and the sun'l from deposits of for pleasure. Many relax by swimming or boating uranium, radium and thonum in the earth's crust; And travel by airplane from radon in the air and radioat tive potassium in These activities continue despite genera' food and water, man has been surrounded by awareness that some 50,000 people are killed in radiation since time began Today these naturally traf fic accidents each year That nearly 6,000 occurnng sc urces expose an individualin the U S to

[3 i

persons drown More than 1,500 deaths are caut.ed by aircraf t crashes immediate and visible in their impact, these dangers are concrete, f amihar. society accepts them almost routinely As a result, thousands of hves most an average dose of about 100 mithrem each ycar.

A mi//irem measures radiation's biological ef fect, as degrees gauge temperature or inches, distance.

This environmental radiation varies widely, depending primarily on altitude and concentration of hkely will be lost this year f rom similar sources radioactive minerals in the ground On coastal plains.

At the same time, many people express concern such as in Flonda, the typical dose per person is about over nuclear energy - about reactor saf ety, f uel 70 milhrem annually; on mountain plateaus, such as shipments, waste disposal - based primanly on fear in Colorado, approximately 165 millirem each year.

that radioactive matenals may be released, that Remaining the largest share - about half - of radiation might harm residents of surrounding man's total annual exposure, httle can be done to communities reduce this inevitable natural background radiation.

This alarm remens even though, during two Just the variations in dose f rom place to place decades of commercial nuclear power in this country. - among which no dif ference in number of health not a single death f rom radiation ever has been ef fects ever has been estabhshed - exceed by f ar observed among the pubhc - even at Three Mile routine public exposures f rom any industrial activity.

Island. And the hkehhood of such a f atahty taking Of the radiation contnbuted by man's technology place in tha future is very small rnost comes from the use of X rays and radioactive Radiation, then, arouses arixiety more for its materials in medical diagnosis and therapy. an averale potential nsk than for its actual hazard: a fo:ce individual dose per year of about 90 milkrem.

considered new, unknown, escaping the senses and Mining minerals, burning f uels, building structures causing unique injunes which may not appear for and other social actions which redistnbute natural many years radioactive elements; f allout from past testing of in f act: nuclear weapons; consumer products such as color o Radiation f rom a nuclear power plant is identical television, smoke detectors, luminous dial watches in physical behavior, identical in ef fect on man, to and miscellaneous sources add approximately that already and always existing in nature. 10 milkrem each year.

e Radiation produces no biologicaldamage that Finally, from routine operation of all commercial does not occur also f rom other natura!, physical and nuclear power plants and all the f acihties in their f uel chemical causes cycle, the calculated average annual dose to an e Radiation af ter more than 80 years of intensive individualin the domestic population today is about study is the most scientifically understood, e&3ily 1/3 of one milbrem.

detected, precisely measured, etf ectively controlled Nuclear energy, then, is only one - and among the ano strictly regulated of all environmental agents least - of the many sources of radiation present in Examining the sources and amounts of radiation society today. Without nuclear electricity, the encountered in everyday hfe, analyzing and companng average American now receives about 200 milkrem their potential contnbution to excess health elfects, annually.With nuclear power, approximately 200.3.

Willlead to f urther understanding and realistic pert pective on this compelhng f undamentalissue.

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. Biological offects of radiation Cautious approach assumed Very large amounts of radiation - f ar above the Sinco it is impossible to demonstrate what harm - i/

levels f ound in daily lif e - can result in early death or any- radiation may bring about in man at common delayed injury, principally cancer and genetic defects. expctures, potential hazards must be calculated Convincing medical evidence that radiation using various scientific theories and mathematical encreases the normal chance of eventually developing pnnciples cancer comes mostly f rom the few groups of people One of the most cautious methods: Assumes that

- pioneors in medical radiology, patients treated possible etfects at extremely low doses are directly with X rays. victims of Hiroshima and Nagasaki - related to known consequences at very high exposures Assumes that any amount of radiation, subrected to massive doses - from tens of no matter how little, involves some risk and there is tnousands to millions of millirem - usually in one or a f ew incdents no level below which no damage occurs Assumes j that several small doses received at intervals produce 1 Many rnore people have been studied extensively

, over several decades to determine if a link exists at the same impact as the sum delivered all at once.

lower levels of exposure Below about 10,000 Assumes that biological mechanisms do not repair millirem, all empenence with human edults generally radiation injury has been negative T he body's reaction to other physical and chemical

Hereditary illness related to radiation has been substances - response decreasing as doses decline, l

? observed only in laboratory espenments with animals lack of insult below minimum levels, recovery from Although it is prudent to assume that similar damage injury - indicates these assumptions most likely may take place in man, none ever has been discovered overestimate radiation's risk to man

- even at e atremely high doses i Both these injuries associated with radiation e

cannot be distinguished f rom those occurring l

naturally and caused t>y other f actors, f urther, they Q:, a ground may r:ot develop f or several decades af ter the m l' esposure assurned to produce them At typical ['

natural and tec hnological doses. there f ore. a Q Soil. Medical

population of hundreds of millions would have to be W x

'005 40 ,

examinations caref ully investigated for many years to reveal any signeficant - statistically apparent - increase in f atal i e

I cancers or inhented disorders That beelth etf ects at relatively low levels of EE(d red ation are too small or occur 50 rarely to be D Diagnostic detected may be part of the problem - but it is also X rays l 12 part of the solutoon j h Cosmic rays ,

t 30 Typical radiation exposures .

~

i (milbrem per individual, '

annually or by activityl ; ;

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"" A "- Radiopharm-L uminous products food. '"*I*

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ekxas 9 Nuclear water f5 weapons 28 We Te6evis.on lh Dental

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ceim ew s i O2 Fallout Xrays i d 5 3 l $

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In the absence of direct experience, however, this cancer Due to the accident: this number might knear, non-threshold formula permits presumed increase - for just one year - to a maximum of elf ects at low doses to be projecNd and compored 4,501.

with the hazards of other activ6es. e About 3,000 of the children born annually would develop serious genetic injuries. From the accident: this figure might rise - for only one year -

Applying the equation to as many as 3,001.

For both these exposures - routine and accidental -

Applying this upper-hmit theory of risk to the various the projected consequences of low level radiation are natural and man-made sources of exposure produces statistical. mathematically inferred results in dose an estimate of the potential contribution of radiation regions where none ever has been - or ever will be -

to health etfects occurnng in the U.S. f rom all causes identified Among the 225 milhon people in this country, from The predicted number of radiation health ef fects environmental and other f actors: among these general and local populations, theref ore, o About 400,000 persons each year die of also could be zero.

cancer Of these f atalities, all radiation might be responsible for approximately 4,500.

e About 390,000 of the children born annually What if, what is will be af fected by hereditary disability Of these illnesses, all radiation might cause approximately 420 in a society of ultimately limited resources - technical,

// radiation at low levels does adversely af f ect man, matenal, financial - the hazards of various activities then, exposure to all sources - natural and technical - as well as the nsks of alternative means to provide a could account for some 1 per cent of all cancer the same benefit must be meaningfully evaluated and mortahty,1/10 of one per cent of senous genetic caref ully compared.

disease, taking place in this country Otherwise, enormous sums may be spent to reduce Even smaller - hundredths of one per cent - would smali nsks even further And much larger hazards be the fraction from radiation associated with might receive relatively httle attention.

commercial nuclear power like any technological process today, the use of s Sim!larly shght is the potential health impact of radioactive materials in medicine, research, industry radiation exposures from the March 1979 accident at and energy production involves a potential nsk :

Three Mile Island on the nearby population, receiving radiation can increase the normal hkehhood of an averageindividualdose of about 1 milkrem Among developing human cancer and genetic disabihty.

these 2 milhon area residents and their of fspnng. However, many other agents - natural, physical, had radioactive materials not been released chemical - also produce these same ef fects And by e About 4,500 persons annually would die of any reasonable estimate, radiation accounts - if at

. all - for a very minor portion of these injuries taking Social . place f rom all causes.

activities Further, much less is known about the levels of harm, hmits of detection, precision of measurement Bnck and ef fectiveness of control for these other materials.

ilding Even were it possible, then, removing radiation from modern society would not significantly reduce z y, cancer mortahty and genetic disease. In f act, by using 1' Wood other methods to perform the same essential services, Hh G , building they might increase.

4 T 30 While continuing to ensure that exposures W

associated with the tremendous benefits of nuclear Air energy are kept as low as reasonably achievable -

' Nuclear Similar effort and resources applied by society to 1

3 energy the hazards of other substances, to the dangers of Fertihrers .

Other activities, would result in rapid, visible 2 7 6 03 improvement in overall pubhc health and safety.

-~-

, _ _ - - _ n -

a, . . , , , . . . . . . , , , _ , , , , ,

l is correct, this does not present any insurmountable obstacle to the implementation of the Clermont County Emergency Plan. It is not argued that the Director of the Clermont County Civil Defense Agency does not have the authority under Ohio law to make the request for aid from others including "any adjoining county and municipal and township officials" in Clermont County or adjoining counties to furnish law enforcement, fire protec-tion and to otherwise assist in responding to an emergency at the Wm. H. Zimmer Nuclear Power Station. Thus, several ap-proaches exist. The Clermont County Sherif f could, for in-stance, be appointed to the Clermont County Disaster Services Agency staf f by the Board of Clermont County Commissioners so that the authority he derived to make the request for assistance ;

^

was through that agency. Alternatively, the Director of the Clermont County Civil Defense Agency could delegate to the Sherif f the task of making the request to the involved of ficials as his delegee.

Both of these approaches were discussed with County and State representatives who found that both appeared to be among reasonable means of resolving the problem and could be imple-mented without undue dif ficulty or delay.

l The treatment and disposition of Contention 20 c5 is simi-

! lar. While, again, it is not proper to consider the legal issue j

raised in this contention, again, assuming arguendo, validity of the legal position proffered in this contention, alternates to l the use of school buses to afford transportation to the general public do exist. As discussed in the Applicants' testimony and I

i l

l 'Ab l 1

in emergency plans, there are CART buses and other transporta-tion resources, including the use of National Guard Vehicles, to transport members of the public to points outside the plume EPZ.

Again, this matter has been generally discussed with the County and State of Ohio and there does not seem to be any insurmount-able barrier to the successful implementation of the Eme rgency Plan, even if the use of school buses was not permitted in an emergency situation.

1 l

l 1

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'26

APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20 c 6, 20 c 10, 36 B, 20 c 12 and 20 c 14 ,

I Contentions 20 c) The public roadways, as access roads for the evacuation l of the EPZ populate of Clermont County, Ohio, and Campbell, Pendleton, and !

Bracken Counties, Kentucky, are inadequate to promptly and timely evacuate -

the involved population.

Specifically. ;

20 c 6) The evacuation time estimates for evacuation of the Clennont !

population, ranging from 1.0 to 3.9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , do not recognize the roadway circumstances >

of Clermont County and evacuation rcuting, the location of residences from ,

public roadways, fails to take into account roadway blockaae due to vehicular i mishap, weather circumstances of the area as reflected by the Clermont DSA time study estimating evacuation times within a range of 2.5 and 77.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , .

fails to consider the character of the population (unprepared as to provisions '

to be transported, inadequate fuel in evacuation vehicle, single vehicle ,

families in which vehicle is at work site, attempts to make telephone contact ;

with police agency to determine if emergency is a test or actual, detouring ;

l from evacuation routes to gather family members not at home, family returning !

to home from off-home site, panic reaction, vehicular mishap, impassable roadways due to flooding, ice or snow and inadequate roadways leading to evacuation routes), paragraphs 1) through 3) and 5), supra, and as such the !

time estimates are grossly underestimated and the population cannot be evacuated .

within the mandatory time limitations. (Clermont Plan, SII-I, Protective l Response, p. II-I-15; Table 3-2, p. 3-7 of Attachment I-2, Stone & Webster r Time Study).

20 c 10) The evacuation time estimates for the evacuation of the ,

Campbell population, ranging from 1.0 to 2.9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , as performed by Stone

& Webster, and ranging from 1.25 to 11.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months , estimated by Kentucky DES, do not recognize the roadway characteristics of Campbell County, the location of residences from public roadways, and fail to consider the character of '

the population (unprepared as to provisions to be transported, inadequate fuel in evacuation vehicles, single vehicle families in which the vehicle is at the work site, attempts to make telephone contact with a policy agency ,

to determine if emergency is a test or actual, detouring from evacuation '

routes to gather family members not at home, family returning to home from '

off-home site, panic reaction, vehicular mishap, impassable roadways due to flooding, ice or snow, inadequate roadways leading to evacuation routes, and the character of evacuation roadways to topography and land characteristics),

and as such the time estimates are grossly underestimated and the population cannot be evacuated with the mandatory time limitations. (Campbell Plan, Annex F, Proteci.ive Actions, Appendix F-18, pp. 3-6 and 3-7.) .

l

27 l

t !

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36 B) The Stone and Webster evacuation time study (Kentucky plan:

Annex F, Appendix F-5 and Campbell County plan: Annex F, Appendix F-18)

! is deficient in several respects and gives a falsely optimistic impression ;

of the ability of the people to evacuate in a safe and timely manner durir.g -

a radiological emergency. (In the following recitation the parenthetical citings after sub-parts 1, viii, and x refer to clarifying addenda that fol mw this contention; all others refer to requirements in Appendix 4 of NUREG- :

0654/ FEMA-REP-1 by section, part and page number.)

l The study: !

i) grossly underestimates evacuation times and the conclusions f are not supported by the assumptions (Addendum 1). ,

ii) does not give estimates of evacuation times for the segment of the non-car-owning population dependent upon public transport (IV-8, p.4-9). l t

iii) does not indicate the critical assumptions which underlie .

the time estimates (e.g., day versus night, workday versus weekend, peak :

transient versus off-peak transient, and evacuation on adjacent sectors versus !

nonevacuation) (IV-A, p. 4-7). ;

iv) does not address the relative significance of alternative assumptions (IV-A, p. 4-7). _'

v) does not make evacuation time estimates for each special i facility on an individual basis (II-C, p. 4-3; IV-B, p,. 4-10). j i vi) does not consider the impact of peak populations including ;

behavioral aspects (IV-8, p. 4-10).

vii) does not make specific recomendations for actions that could be taken to significantly improve evacuation time (V, p. 4-10).

viii) contains errors in measurements of road widths that could [

influence calculations of road capabilities and result in additional underestimations ;

of evacuation times (Addendum 2). !

ix) does not contain comments by the principal organizations i i resulting f rom their review of a draf t submittal of the study (V, p. 4-10). :

x) contains unresolved conflicts of great proportions between ,

evacuation i.ime estimates by Stone and Webster and those by the Kentucky l Disaster and Emergency Services, the Ohio Disaster Services Agency, and the i Clermont County Disaster Services Agency (Addendum 3). -

Clarifying Addenda To Contention 36 B

1) At the prehearing conference Mentor used the following example.

The best estimate evacuation time with prompt notification time for the 0- i

2 miles zone in Sector II is given as 1.0 hours0 days 0 hours 0 weeks 0 months (Table 3-1). An evacuation l

)

'26

time is the sum of the notification, preparation, and travel times (p. 4-

1) for the 0-2 miles zone in Sector II; notification time is .25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months (Table 3-1) ar.d preparation time is .50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months (p. 5-7), whose sum is .75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months .

This leaves a travel time (not given) of .25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months evacuation time minue .75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months preparation and mobilization). Assuming an evacuee must travel 8 miles to get outside the plume exposure EPZ, he must travel at 32 miles per hour (8 miles in .25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months ). The study, however, assumes a rate of only 25 miles per hour (p. 5-7). The study further assumes a distance of twice the radial distance to the edge of the evacuation zone (p. 4-1).

The evacuee, then must travel at 64 miles per hour rather than 25 miles per hour to reach to edge of the plume exposure pathway.

The applicant has since then interpreted " edge of the evacuation zone" to mean " edge of the 0-2 miles zone" rather than " edge of the 10 miles evacuation zone" which Mentor had assumed. Under this interpretation the above calculations are obviously not correct. However, because the City has not had time to study the rest of Table 3-1 with this interpretation in mind and because this interpretation raises new problems about warning times, plume speeds, road capacities, etc., that influence evacuation times, the City is not ready to withdraw this part of this contention.

2) Table 5-1 (pp. 5-9 to 5-11) names evacuation routes and gives the number of lanes, width of lanes, and the average capacity in vehicles per hour of each road. A spot check of road widths in Campbell County (SR 8, SR 10, US 27, and CR1121) revealed that not one of them is as wide as the table indicates.

Evacuati on Width Implied Actual Width Route by Table 5-1 by Spot Check SR 8 24 20 SR 10 20 17.25 US 27 24 22 CR 1121 20 15.5 Table 5-1 gives the average capacity as 1000 vehciles per hour for each of these roads, but does not indicate whether this figure is for volume in one direction or both directions, and cites Transportation and Traffic Engineering Handbook as an authority. If 1000 vehicles per hour average capacity is for travel in one direction (a reasonable assumption, since the discussion is about evacuation in one direction), cursory look at the reference show that this figure is pure fantasy. Table 8.9 p. 331) gives the maximum service volume in both directions under ideal conditions on two-lane rural highways as 2000 vehicles per hour. Short passing sight distances, low average highway design speeds, narrow lane widths and small lateral clearances, the combination of low performance vehicles and grades, as well as driver psychology are among the factors that reduce service volumes considerably. If the 1000 vehicles per hour average capacity is for travel in both directions, then that qualification is inapplicable and inappropriate in the context of one-way evacuation and the figure is still inflated and subject to modifying factors.

i N,b 1

I t

3) Table 3-2 (p. 3-7) compares Stone and Webster evacuation time i estimates and those of KyDES, ODSA and CCDSA. With two exceptions the Stone

! and Webster times are invariably lower than the others. Differences between Stone and Webster and KyDES with prompt notification considered range from j

.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months to 7.85 hours9.837963e-4 days 0.0236 hours 1.405423e-4 weeks 3.23425e-5 months . Differences between Stone and Webster and ODSA and i CCDSA without prompt notification range from .7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to 60.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In a j "run for your life" situation when minutes count, these differences between planners raise the question of the veracity of radiological emergency response .

plans written by the same people. I i

20 c 12) Evacuation time estimates are inadequate for the reasons ,

presented in paragraphs 6) and 10) supra and this plan again sets forth the l Stone & Webster study. j 20 c 14) Evacuation time estimates are inadequate for the reasons !

presented in paragraphs 6) and 10) supra and this plan again sets forth the L Stone & Webster study.

l Testimony Evacuation time estimates are provided to planning officials as ,

an aid in making decisions regarding protective actions for the plume Emergency Planning Zone. During a radiological emergency, planning officials may be L

required to recommend the imolementaticn of the protective actions of sheltering !

[

or evacuation to minimize the radiation exposure of. the potentially affected (

i population. The basic evacuation time estimates are only used in the decision

[

making process. Using the time for evacuation of the public along with other f information such as projected dose rate and exposure duration, public officials !

will determine which protective action (sheltering or evacuation) will result in the lowest possible exposure of the population.

It is impossible to predict in advance what factors or combination t

of factors will exist at the time of an evacuation. Rather than trying to j predict evacuation times for every conceivable condition or combination of i conditions, time estimates have been provided for two conditions, a best estimate and an estimate for adverse weather. Should conditions exist at the time of a potential evacuation that in the judgment of the public officials would significantly increase evacuation times, two actions can be taken.

First, actions will be taken, as provided for in the plans, to eliminate l

30 ,

, , ,- - ---,,~,-n,

f t

i the condition (e.g. removal of disable cars, prompt clearing of snow, designation l of alternate evacuation routes) that expedite the evacuation. Second, local officials can modify the evacuation time estimates based on the conditions ,

existing at the time of the evacuation, should these conditions, based on the judgment and experience of the planners, increase evacuation times.

> The modified evacuation times would then be used in the protective action ,

j decision making proc.ess. Thus the sole use of evacuation time estimates i

is in protective action decision making. The times are provided as a guide l to the time it would take the public to evacuate under the study conditions. l To that end, the times are only estimates and are not " mandatory time limits." -

There are no " mandatory time limits" for the evacuation of the public. l The evacuation times developed by Stone & Webster were prepared {

in response to a request by the Nuclear Regulatory Commission in a letter '

dated December,1979. In that letter, no analysis technique was specified. :

Later guidance regarding evacuation time estimate calculations was set forth !

in NUREG-0654/ FEMA-REP-1 Revision 1, Appendix 4. The guidance in this document I indicates that dynamic analysis for the preparation of evacuation time estimates !

is one acceptable method. When the results of Stone & Webster are compared to the times obtained by the dynamic analysis method for nine nuclear power f plants (Table 1), close agreement results. The evacuation times from the l Stone & Webster study are within the range of values and are in fact higher !

l i

than the times for all but one of the sites during normal workday conditions, i i

and two for adverse weather conditions. l Table 1 also compares the evacuation times submitted in response to the 1979 NRC request to a dynamic analysis of evacuation times prepared f for those plants by FEMA. In all cases, the dynamic analysis resulted in lower times than the earlier analysis for that plant. This indicates ,

{

31 i

_ - .. . -. =. ..

that if the Zimmer EPZ evacuation time estimates were reevaluated using dynamic analysis techniques, the estimated times for evacuation would likely be comparable or lower than those presented in the plans.

The times presented in the evacuation time estimate are adequate

for the use of emergency response officials in the decision making process for protective actions.

Specifically addressing the items raised in the contention:

The evacuation time estimate considered the local road network in the development of the evacuation routing information developed for that study. As that study stated on page 5-4:

1

" Considerations in the selection of routes included:

(1) the recommendations of state and local official and planners,"

Local officials and planners are familiar with any local considerations and restrictions on the use of these routes.

The location of residences from public roadways, private lane distances and road conditions alcag such roads do not restrict normal daily travel

, and during an evacuation no traffic flow on these lanes is expected to exceed t

1 3

their capacities.

1 There are provisions in the plans for dealing with roadway blockage due to vehicles mishaps and the designation of alternate routes should routes 1

become blocked during particularly severe weather. In addition, procedures exist which direct the public officials to modify the evacuation times for an evacuation to be taken during conditions which could significantly delay travel, such as snow or fog.

l 3'2

1he general population will be prepared for evacuation by the provision of public information, including a discussion of evacuation, in an emergency planning booklet distributed to every business and residential address. l This booklet, entitled " Circle of Safety", is attached to Dr. Klare's testimony in draft form. Contained in that booklet is specific information regarding evacuation including: notification methods, materials to be taken during evacuation, a procedure for identifying special transportation needs, and a map indicating suggested evacuation routes and relocation centers. The booklet also contains specific information indicating the method for initial 1

notification of the public and the means for providing instructions to the j l

public for the taking of the protective actions. '

For developing the evacuation time estimates the maximum distance that would need to be travelled to be out of the area was assumed to be twice -.

the radial distance or 20 miles when evacuating an area to a 10 mile radius.

A minimum amount of fuel would be required to travel such a distance. It is expected that nearly all vehicles would have sufficient fuel to travel out of the EPZ. However, should vehicles run out of fuel, transportation would be provided by other private vehicles or by county vehicles specifically designated in the plans to serve persons without transportation. Vehicles inhibiting evacuation could be bypassed, or moved to the side or off the road. Alternate routes could also be recommended based upon traffic flow.

The time required for vehicles away from home to return to the home is included in the mobilization time assumed in the preparation of the study. Should the time for the vehicle to return be in excess of that required for evacuation, transportation could be provided in accordance with the plan provisions for those without transportation and families could reunite at reception centers outside the EPZ.

33

The public infonnation booklet instructs the public not to call local law enforcement agencies. Notification of the public and subsequent information instructions will be provided by the prompt notification system I and messages on the Emergency Broadcast System. These messages will clearly indicate whether the event is a test.

i Families returning to home from off-home sites within the EPZ area to be evacuated are expected to be able to mobilize in the times presented in the study. Families attempting to return to homes from outside an evacuation area may be prevented from entering by access control personnel and told to go the the relocation center designated for the area. i

" Panic reaction" would not appear to be a problem based on the following information presented in Evacuation Risks - An Evaluation, U.S.

Environmental Protection Agency, Hans & Sell, June 1974, which concluded, .

af ter examination of a number of emergency situations: t "A state of panic does not exist during an evacuation which would result in reckless and high-speed driving (18). The evacuations were very orderly and vehicle traffic tends to move at relatively low speeds (35 mph is the average)." ;

i In the event of a Zimmer related evacuation, panic reaction and other psychological j factors are expected to be minimized due to the public information program's preparation of the public to take proper protective action. ;

Vehicular mishaps and weather related roadway blockages have been discussed above.

The evacuation time estimate was prepared assuming that the non-auto owning population would evacuate within the estimated times. There is no reason to believe that the segment of the population could not evacuate i t .

within these times. First, the experience of state planners is that non-34

J l

auto owning persons find some means of evacuating, usually with a neighbor l or nearby relative. The " Circle of Safety" public information booklet encourages this. This booklet makes additional provisions for the handicapped, by providing a mail-in which will aid in identifying these people. Special provisions for transporting the people identified in this process can then be made.

The evacuation time estimate provides information based on those assumptions presented in the study in Section 5, Considerations and Assumptions.

Alternate conditions will be evaluated by planners as part of their protective action decision making process.

The evacuation time estimate in Table 5-3 presents evacuation data for each of the special facilities considered in the study. The information includes the estimated mobilization time for each facility. This information was obtained from discussiens with local planners, school officials, and special facility operators. The evacuation times for each facility were then calculated by combining the mobilization and evacuation travel times 1 and the maximum total time per zone for special facilities was presented on Figure 3-1.

The evacuation time estimate considered the maximum permanent population as stated on page 5-6:

" Total population information, which includes resident population, school childeren and area employees, results in a high estimate of the total population to be evacuated due to probable " double counting" of some residents who live, as well as work, in the area, and school children who live, as well as attend schools in the planning zone."

Since the evacuation times determined by the study were relatively short, no reconnendations as to significant improvement were considered possible.

The basis for the capacity of 1000 vehicles per hour on the evacuation t

3b

i routes was the Highway Capacity Manual, Highway Research Board,1965. On page 76 of that document Table 4-1 presents the capacity for a two-lane, i

two-way road as 2000 vehicles per hour. In the text that accompanies that t table it is indicated that the one direction capacity would be half of that or 1000 vehicles per hour. The allegation that this is a " fantasy" figure is incorrect. As the text indicates on page 76, these capacities are based on actual roadway conditions. Specifically: !

" ... these values were determined from studies of many highways ,

1 under a variety of conditions. In all cases it would be impossible

! to state that the volume measured was the absolute maximum that l could be carries, inasmuch as maximum volumes observed at different times at one point will show a range of values. Rather, each capacity value given in Table 4.1 should be considered as the average maximum volume, or a maximum volume that has a reasonable expectation of occurring frequently (underline added) on the particular type of highway under ideal conditions." !

An analysis of the effect of reduced roadway capacities on evacuation ;

times was made during the preparation of this testimony. This analysis indicates that the evacuation times predicted by the Stone & Webster study would increase i only slightly even if significant reductions in capacity are assumed. Evacuation times were calculated after assuming a roadway capacity reduction of 50%

(500 vehicles / hour). The times were found to be unchanged in six of the i ten zones. In the four zones where changes occurred, increases of 8, 10, 15 and 34 percent resulted. !

Similarly, evacuation times were calculated using roadway capacities 1

reduced by 25% (750 vehicles / hour). In this case evacuation times in nine -

of the ten zones were unchanged and the time in one zone increased by 24 percent.

36

1 l

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1 In July 1981, state and local planners for both Kentucky and Ohio reviewed the evacuation time estimate during their review of draft plans.

No comments on the evacuation time estimate were received from any party.

Evacuation time estimates depend on the assumptions and methodologies used in their preparation. It is not known what assumptions and methodologies the Ohio and Kentucky planners used in the preparation of their estimates.

Therefore, a comparison of these estimates with the Stone & Webster study is not meaningful. While differences in the times estimated by Stone & Webster and those estimated by local planners exist, the Stone & Webster study is adequate for its intended purpose.

The City of Mentor has incorrectly interpreted the " edge of the evacuation zone" to mean the " edge of the 10 mile evacuation zone" rather than the " edge of the 0-2 mile zone as specified in the NRC request." This .

incorrect interpretation has resulted in a meaningless calculation.

The evacuation time with prompt notification for the 0-2 mile zone in Sector II is 1.0 hours0 days 0 hours 0 weeks 0 months (Table 3-1). Since the study states on page 4-1: " Evacuation *ime estimates (were) obtained by adding the estimated notification, mobilization, and evacuation travel times." Subtracting the notification time of .25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months and preparation time of .50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months from the evacuation time estimate of 1.0 hour0 days 0 hours 0 weeks 0 months results in a travel time of .25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months . The study on page 4-1 assumed: "The travel times were conservatively estimated by assuming a travel distance of twice the radial distance to the edge of the evacuation zone." Not allowing for the distance of the river and assuming a person started at the plant, a distance of 4 miles would be traveled. Traveling the 4 miles in .25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months would result in a speed of 16 miles per hour versus the 64 miles per hour the city of Mentor calculated. This is lower than the 25 miles per hour assumed by the study (page 5-7) and is a further conservative element in the determination of the evacuation times.

37

1 i

j TABLE I - Maximum Evacuation Times of the 10-Mile Emergency Planning Zones for Nine Nuclear Power Stations Compared to the Results of the l Wm. H. Zimmer Evacuation Time Estimates f

i Nuclear Power Station Normal Workday Adverse Conditions Responses to NRC Responses to NRC Letter of 12/79 (1) FEMA-REP-3 Letter of 12/79 (1) FEMA-REP-3 i

Wm. H. ZIMMER 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 10 minutes 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 55 minutes

) 1. Bailly (2) 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months (2) 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 10 minutes

2. Beaver va lley 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 45 minutes (3) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 5 minutes 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 15 minutes (3) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 10 minutes

3. Enrico Fermi (2) I hour 55 minutes (2) 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 25 minutes t

4. Limerick (2) 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 10 minutes (2) 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 10 minutes tl4 Gt 5. Maine Yankee 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 50 minutes 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 10 minutes 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 25 minutes 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 55 minutes j 6. Midland (2) 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 30 minutes (2) 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 55 minutes

7. Millstone 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months 35 minutes 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 5 minutes 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months 5 minutes 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 25 ninutes

!' 8. Shoreham (2) 2~ hours 35 minutes (2) 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 55 minutes f '

9. Three Mile Island 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months (3) 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months (3) 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 20 minutes (1) Data from Nureg/CR-1856, PNL-3662 Volume 2, May 1981.

(2) Data Not Available.

(3) Indicates results in which NRC has poor confidence.

t r

r s:

sg.

APPLICANTS' TESTIMONY REGARDING CONTENTION 20 c 7 and 36 C Contention 20 c) The public roadways, as access roads for the evacuation of the EPZ populate of Clermont County, Ohio, and Campbell, Pendleton and Bracken Counties, Kentucky, are inadequate to promptly and timely evacuate the involved population.

Specifically.

20 c 7) The evacuation of the Campbell County population directed in a generally north direction of Persimon Grove Road to proceed in a generally northwesterly direction on evacuation routes Ky 10 and Ky 8 are inadequate where the plume pathway of radiation release from the Zimer Station is generally northwesterly proceeding in the same path as the evacuation routing, and is inadequate in the failure to evacuate that pcrtion of the population away from the plume pathway; and the evacuation of the Campbell County population directed in a generally south direction of Persimmon Grove Road to proceed in a generally westerly direction on evacuation routes 1121, 1280 and U.S.

27 are inadequate where the plume pathway of radiation release from the Zimmer Station is generally westerly proceeding in the same path as the evacuation routing, and is inadequate in the failure to evacuate that portion of the population away from the plume pathway. Implementation of the evacuation under the stated circumstances provides no reasonable assurance that the -

health and safety of the affected population is protected. (Campbell Plan, Annex F, Protective Actions, p. F-14-1.)

36 C) There are no provisions for alternate evacuation routes or for evacuation in opposite directions on the provided routes in consideration of differenct radioactive plume directions, traffic congestions, or impassable roadways. Maps in Annex F of both plans have arrowheads pointed. inexorably in fixed directions and the Kentucky Division of Disaster and Emergency Services has publicly stated that no consideration whatsoever will be given to changing the plans in this respect. Since Appendix 2 of NUREG-0654/ FEMA-REP-1 is devoted entirely to meteorlogical measurements and predictions of atmospheric effluent transport and diffusion and criterion J-2 provides alternate evacuation rcutes for onsite indiviuals, the regulations clearly imply, and common sense dictates, that the general public should be able to flee away from a radioactive plume rather than be forced to pass through it.

Testimony .

The selected evacuation routes are adequate for evacuation of the population in Campbell County.

The planning basis for the selection of evacuation routes is provided in NUREG-0654/ FEMA-REP-1 and states that "aacuation shall be based o'n a general radial dispersion."

33

. _ _ . . - . = . -_ - . .- __ _ _ _ _ . .

I i

Evacuation is only one of the possible protective actions available t i to public officials for recommendation to the general public. Evacuation f is reconnended only when sufficient time is available prior to a release i to implement that alternative or3 in the case where a release is in progress, when a significant savings in radiation exposure can be achieved.

The roads chosen as evacuation routes out of Campbell County are !

those that allow for a safe and timely evacuation of the public. The evacuation f; routes shown in the plan are not the only routes that will necessarily be {;

used in every circumstance. Temporary conditions on any road may result l

in County officials specifying alternate evacuations routes, if necessary. f

?

i Y ,

i f

[

i f i l i

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APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20 C 8, 36 D, 20 C 11, 20 C 13 Contentions 20 c 8) Campbell evacuation routes 1121, California Cross Road and Persimon Grove Pike are narrow, winding and hilly with steep inclines; Lickert Road has four 90 degree turns and a narrow bridge impeding evacuation and where it intersects U.S. 27 there is no access point control to direct traffic flow resulting in traffic blockage or accident; Ky 8 is narrow without road berm, or shoulder, and approximately one-half mile southeast of Oneota for an approximately distance of one-fourth of a mile the road has eroded and been without repair for a substantial period; Wesley Chapel Road and 1197 are narrow, hilly ridge roads; Ky 10 is a narrow winding ridge road and parallels 12-Mile Creek and during flooding this portion of Ky 10 is impassable; and the approximate 50 rural service roads that the population must travel to evacuation routes are approximately 12 feet wide without centerline, some gravel roadways leading to evacuation routes, due to topography and land characteristics, are not capable of affording prompt and timely evacuation of the population. (No plan provision).

36 D) A designated major evacuation route, Kentucky Route 8, is dangerous in places for ordinary use and obviously unfit for emergency evacuation purposes. In particular, south of Twelve Mile Creek the road is built into the side of a steep hill and is frequently subject to slippages, some of them so severe that the north bound lane has been practically unusable for weeks at a time. Piles have been driven recently in an effort to support the roadway, but the road surface is dangerously irregular and convoluted and would be particularly hazardous during emergency evacuation conditions.

20 c 11) Pendleton Cour.ty evacuation routes Corntown Road, Ky 10, Flour Creek Road,159, Concord Caddo Road and Falmouth Lenexburg Road are ridge roads, steep, narrow, winding and in areas limited to maximum speeds of 25 mph; and the approximate 20 rural service roads that the population must travel to evacuation routes are approximately 12 feet wide without centerline, several gravel roads, winding and hilly; the evacuation routes and access roadways leading to evacuation routes, due to topography and land characteristics, are not capable of affording prompt and timely evacuation of the population.

(No plan provision). ,

20 c 13) Bracken County evacuation routes Ky 10, 1109 and Ky 8 are ridge roads, steep, hilly narrow and winding and the approximate 10 rural service roads that the population must travel to tne evacuation routes are ,

approximately 12-foot in width without centerline, winding and hilly and incapable of affording prompt and timely evacuation of the population. (No plan provision).

11

Testimony The roads chosen as evacuation routes in the Kentucky County plans provide for a safe and timely evacuation of the public. The routes chosen are as suitable for use during an evacuation as they are for day-to-day travel.

During an evacuation, more vehicles may travel over the given routes, however, other road conditions would be the same as during any other day.

The principal evacuation roadways are paved. The majority are State or U.S. numbered highways and generally have centerlines. The gravel roadways and other access roadways will only be required to provide access to evacuation routes, a function no different from that provided on a daily basis.

Temporary conditions on any road may result in county officials specifying alternate evacuation routes, if necessary. The conditions of the particular roads cited will not prevent passage because although the road surface is irregular, the traffic can still pass over it.

I l

12

t APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20.c.9, 24.10 AND 36.G f Contentions f l 20.c.9). There are an inadequate number of school bases to timely and (

promptly evacuate. students of the nine schools within Campbell County subject to plume exposure, and during school session evacuation the use of school buses as vehicles for evacuation of the general public without transportation is incapable of af fording timely and prompt evacuation of that segment of tne population; there are no posted school bus stops or ro utes and there is no plan provision to educate ;

the public where they a re to assemble for school bus transportation to -

afford timely and prompt evacuation of that segment of the population; i the roadways within approximately eight miles of the Zimmer Station !

l are inadequate fo r TANK bus travel and maneuve rability. The plan is [

not capable of being implemented in a timely and safe manner to ;

evacuate that portion of the popula tion without pe rsonal vehicles. !

(Campbell Plan, Basic Plan, pp. 5 and 6; Annex, Protective Actions, p. i F-9-1.) I i

} 24.10). The procedures in Clermont and Campbell Counties to acquire l lists of disabled, handicapped and senior citizens requiring special [

transportation fails to provide reasonable assu rance by the plan or in i its implementation that all such individuals are identified and that adequate vehicles and personnel are available and dependable to enter -

the plume exposed area to evacuate such individuals. (Clermont Plan, ;

II-B, Emergency Response Support, p. II-B-T, Protective Response, p. !

II-I-5; Campbell Plan, Annex F, Protective Actions, p. F-9-1).

J

36.G). Plans fo r the sa fe and timely evacuation of people without [

t personal vehicles and for those who are elderly, handicapped, confined :

or otherwise incapable of evacuating themselves are rudimentary, !

j inadequate, undeveloped, and unworkable. The proposed Campbell County i plan fo r such people calls fo r their evacuation by school buses and l through the assistance by the Eastern Campbell County Volunteer Fire {

Department (Annex F, Appendix F-9, II, p. F-9-1 and III-C, p. F-9-1). l The schools lack sufficient buses to evacuate school children (see !

Contention 36E, consolidated with Contention 21) and cannot provide l l buses for this purpose; the fire department is not capable of i providing this assistance (See Contention 36H, consolidated with f Contention 20.e.7). i Testimony [

i !

i l There are an adequate number of school buses to evacuace the l studer.ts of the nine af fected Campbell County schools as well as to ft j provide transportation resources fo r th at segment of the population !

without private vehicles. !

! l 4

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An evacuation of the Campbell County Schools would be accomplished with 58 school buses and 2 lift buses. The plan provides for additional assurance with the supplemental use of a considerable number of privately owned vehicles, especially at the high schools,

and ten TANK buses. The roads designated as evacuation routes fo r l i schools are regularly travelled routes chosen to be accessible to buses. See Contention 21.C.4 for further information concerning school evacuation.

)

The use of school buses fo r the general public without their own transpcrtation would apply both during non-school hours and when school is in session, as the buses become available after the schools have been evacuated. Campbell County plume exposure EPZ schools will be evacuated in advance of any anticipated or potential need fo r recommendation of an evacuation of the general public, if possible.

Under these circumstances, there would be sufficient time to evacuate -

all school children and those of the general population who need transportation. In the event of a lack of transportation fo r the general population, the plan provides for additional resources to be supplied by:

1. Transit Authority of Northern Kentucky (CCREP, Annex M. Section IV-A, page M-2)

2. Campbell County Police (CCREP, Appendix F-9 Section IV-A, Pa g e F-9-3 and Anney M, Section IV-A, page M-2) l l

l

3. Community Actions Commission (CCREP, Annex M, Section IV-A, page M-2 and Annex P; Letter of Agreetaent) Available resources: 10 vehicles 11

4. Northern Kentucky University (CCREP, Annex P, Letter of Agreement) l b

Available resources: 2 buses, 5 vans, 4 station wagons, 1 cargo l k van and 3 trucks !

[

5. Kenton County Board of Education (CCREP, Annex P, Letter of I I

Agreement) Available resources: 120 vehicles !

l i

Those needing this transportation will be provided ;

instruction as to when and where to assemble. Pick-up paints are j 1 along the roads. 5 I

I I

In the event of an evacuation, those at Camp Sunshine without !

transportation will walk to the Eastern Campbell County Volunteer Fire l Department, which is across the road from the camp entrance t

(approximately a five minute walk) for pickup and transport to campbell County High School by County resources including possibly ;

County and State police. The camp, however, is open only during the !

i

summer months and averages fifty in attendance at any time, including '

staff. No transportation function has been assigned to the Ea s te rn i

Campbell County Volunteer Fire Department except eme rgency {

transportation as requested. [

The Clermont and Campbell Counties plans adequately provide i for the identification of disabled, handicapped and senior citizens, and the vehicles and personnel to transport them in the event of an

evacuation. In general, there are two means of identifying those with special needs: $

)

a. The " Circle of Saf ety" notifies all such people to identify i

themselves, whether their condition is permanent or i t

l *Ib l - _ _ _ - _ - _ .-. . . . ~ - - - -. - . ~ - . - . _ . - - . - . . . - .. _ - - _ . - . . . - - . - , . . ---

\

temporary, to the appropriate planning organization. A paid-reply postal card is provided for that purpose.

b. Absence of the "I have been notified" card in the window will summon help. Local emergency response personnel will perform door-to-door verification checks driving along all roads in

the EPZ and will stop at all residences not displaying a notification messa e ta see if assistance is required.

In Campbell County, updated lists of handicapped or senior j citizens will be maintained by the Judge / Executive's Office. The

(

" Circle of Safety" will provide ample opportu ity to these residents to identify themselves fo r inclusion on these lists, and thereby secure transportation in an emergency. TANK (Transit Authority of i

Northern Kentucky) will provide the transportation, with additional assistance from fire and rescue personnel, as necessary. Local -

i

! emergency response personnel will also peiform a door-to-door inspection of the evacuated area and check all homes in which the "I have been noti fied" ca rd is not displayed. (Campbell County Plan F 1, M-2, Annex J.)

)

In Clermont County, updated lists of handicapped or senior

, citizens will be maintained by the County DSA, as well as the Clermont Senior Services and CAPH/DD. The " Circle of Safety" will provide i ample opportunity to these residents to identify themselves for inclusion on these lists and thereby secure transportation in an emergency. As the Clermont County plan states: "The County Welfare i

Department (CWD) and the Clermont Association for the Physically

Handicapped / Developmentally Disabled (CAPH/DD) will provide their most 1

updated lists of handicapped and, therefore, transportation dependent l

16

residents of Clermont County, (will be identified) at the time of an emergency. Both CART and CAPH/DD have drivers and vehicles capable of moving handicapped persons. The Clermont Senior Se rvices (CSS) will provide updated information on transportation dependent senior citizens in Clermont County at the time of an emergency. Local life squads may also support the transportation of the handicapped and senior citizens, in addition to transporting patients and residents of the Dobbins Nursing Home in New Richmond, Ohio. Ambulance support is also available from the Ohlo National Gua rd units identified in Figure 1, Section I-1, of the State Plan." (Clermont County Plan II-I-5) .

Local emergency response personnel will also perform a door-to-door inspection of the evacuated area and check all homes in which the "I have been notified" ca rd is not displayed.

9 i

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APPLICANTS' TESTIMONY REGARDING CONTENTION 20 c 9a Contention 20 c) The public roadways, as access roads for the evacuation of the EPZ populate of Clermont County, Ohio, and Campbell, Pendleton and Bracken Counties, Kentucky, are inadequate to promptly and timely evacuate the involved population.

Specifically.

20 c 9a) Access control points are inadequate in number and placement to direct and control traffic during evacuation and the plan does not provide any reasonable assurance that an adequate number of police and other support groups are available to discharge the responsibility and police and support groups are insufficient in number to be timely deployed to control evacuation traffic. (Campbell Plan, Basic Plan, p. V-7; Annex F, Protective Actions, pp. F-10-1 and 2; Annex G, Law Enforcement, p. G-1-1: other than a statement of the identity of police units, no information is provided as to number of personnel, vehicles and equipment to provide reasonable assurance that the plan is capable of being implemented).

Testimony The Campbell County Plan provides reasonable assurance that designated access control points will fulfill their intended function in the event of an evacuation.

The establishment of access control points designated in the plans is not intended as a requirement to proceed with an evacuation. Indeed, an evacuation may be ordered before any access control points are established.

If established during an evacuation, access control serves to keep unauthorized persons outside of affected areas, and as a secondary benefit when possible, direct evacuees. Their primary function is simply controlling access'into the affected area.

The Campbell County Judge / Executive, based on information from

, ZPS-1 and the County DES Director concerning direction of plume travel and I

affected sectors, and information from the County Engineer on weather and i

road conditions, may alter access control points from those designated in i the plans to control access at different points, or to direct the flow of l traffic to routes that will eliminate or minimize plume exposure.

16 l - - - -- - .

These points will be manned by county law enforcement and fire personnel, supported by Northern Kentucky University bonded security guards.

If additional personnel are required, the County DES Director will call upon the Kentucky State Police and National Guard to supply them.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 20e3 Contention Clermont County has only volunteer fire squads. Fire personnel are assigned supporting access control action as available and no dependable count is furnished by the plan. Fire personnel within the plume area will provide door-to-door verification of population notification consisting of 313 volanteer personnel and 28 vehicles with an additional combined fire and life squad group of 334 (fire personnel numbers not stated in plan) to perform tasks in either the plume or relocation area and equipped with 18 vehicles.

The plan fails to indicate the number of volunteer fire personnel that would or could be available at the time of emergency. The approximate number of j

tire personnel available on shift at notification for initial service would be 38. The miles of roadways within the plume area, together with the miles of country lanes involved, remove any reasonable assurance that fire personnel of 38 to 267 (assuming all volunteers could and would immediately respond) to facilitate door-to-door verification of notification within the plume area and the miles of roadway present. The plan presents no reasonable assurance or upon implementation that any one, more or all of the volunteer fire personnel would or could be present to assume the responsibilities assigned, or that such personnel would or could leave their regular employment and family responsibilities during evacuation. (Clermont Plan, p. II-I. Protective Response, P. II-3-6, III-8, Emergency Services, pp. III-8-2, 5 and 7.) -

Testimony The Clermont County Radiological Emergency Response Plan adequately provides for the fire departnents within the Plume Exposure EPZ to respond to an emergency

, at ZPS-1.

The attached tables from the Clermont County Emergency Response Plan provide the correct information concerning fire and life squad resources, including personnel.

Personnel for access control during take shelter or evacuation is to be provided by local police departments, the Ohio State Patrol, the Ohio National Guard and the Sheriffs Office. Fire department personnel are only assigned a supporting role, and will only respond when personnel availability permits.

Manpower for access control can be provided from the other sources, if necessary.

b0l

According to the Clermont County Plan, the public living within the plume exposure pathway EPZ will be notified in the event of a Site Emergency or a more severe emergency occurring at ZPS-1 by means of the integrated Prompt Notification System. This system will consist of the use of sirens and NOAA weather radios.

This system is supplemented by door-to-door verification, and the Emergency Broadcast System (EBS). It is designed in accordance with NRC/ FEMA guidance.

The public will be instructed, via periodic public information/ education programs, to signal they have received notification and are tuned to their EBS or NOAA station for further updates. This is accomplished by placing a green "I have been notified" card so that it is visible from the road.

A towel tied to a door knob or mailbox visible from the road will serve as an alternative to the card. During an evacuation, if a member of the public has received notification but needs assistance (i.e. transportation due to ,

a handicap or lack of an automobile), they will not display the "I have been notified card" or towel. Door-to-door checks of all households which have not displayed the card or tcwel will identify persons who require assistance.

Pre-exercise training sessions and discussions were conducted with local fire departments involved in door-to-door notification verification.

Fire department personnel will travel the roads of the sectors which are in their jurisdiction using private vehicles as well as regular emergency vehicles. Fire department personnel are local people, and the routes to be followed are roads with which they are familiar. Thus, local road knowledge, and ample fire department personnel and equipment will allow timely door-to-door notification verification.

l bl 1

f i

'~'

Agencies composed of volunteer workers recognize that not all volunteers will !

m- ~ ,

j _ always be able to respond tc an emergency. A number of fire department and !

1 t

life , squad personnel live and work near their assigned fire stations. They !

,_., can edsily7et' pond to an emergency when at home and many have verbal and/or i written ~ agreements with their employers allowing them to leave when an emergency i

,- t arises. .,

s !

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l TABLE III-B-3 t

j Local Fire Departments Resources Chart *

~

1 Fire Number of Radios Personnel Department Fixed Pagers Plectrons Mobile Portable

{

1 e Anderson Twp. 3 2 20 30 45 I F.D. & L.S.

i J

! Batavia F.D. 0 30 4 20 30 i.

l Bethel-Tate 0 40 8 1 38

{ F.D.

BMOP F.D. 0 48 10 8 48 1 & .S.

Day Heights F.D. 4 4 30 I.

1 Felicity Franklin 1 25 4 2 25-F.D. +

t l Goshen Community 5 F.D.

{

4 -.

l .i Loveland Community F.D. -

Miami East F.D. 6 Miamiville F.D. -

j Milford F.D.

Monroe Twp. 0 25 5 4 25, i F.D.&L.S.

1 l New Richmond 1 5

F.D.

North Union Twp. 1 8 8 45 i F.D.&L.S.

i i

,

Distribution of radiological monitoring equipment is given in Table G-5,

{ Section II-G.

l i

l ~

l b3

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]

~

l TABLE III-B-1

(* Emergency Services by Response Category Plume EPZ Response Relocation Center Response Bethel-Tate Police Department Amelia Police Department Fecility-Franklin Police Department Batavia Police Department Monroe Township Police Department Goshen Township Police Department Moscow Police Department Loveland Police Department New Richmond Police Department Miami Township Police Department Pierce Township Police Department

Milford Police Department Newtonsville Police Department -

Bethel-Tate Fire Department Owencville Police Department BHOP Fire Department and Life Squad

Union Township Police Department Felicity-Franklin Fire Department Williamsburg Village Police Department Monroe Township Fire Department New Richmond Fire Department Anderson Township Fire Department North, Union Township Fire Department and Life Squad

and Life Squad

Batavia Fire Department Pierce Township Fire Department Day Heights Fire Department and Life Squad

Goshen Community Fire Department Washington Township Fire Department Loveland Community Fire Department

. Miami East Fire Department Bethel-Tate Life Squad Miamiville Fire Department Felicity-Franklin Life Squad Hilford Fire Department Monroe Township Life Squad Owensville Fire Department Wayne Township Fire Department

'.,,, Moscow Life Squad Williamsburg Village Fire Department New Richmond Life Squad and Life Squad Withamsville Fire Department

Indicates that this agency is likely to provide either Plume EPZ or Relocation Center Response, but is listed in category of most expected response.

i i

e e

b1

TABLE III-B-3 (con't)

??

Y.

4 Fire !! umber of Radios Personnel Department Fixed Pagers Plectrons Mobile Portable Owensville F.D.

Pierce Twp. 2 35 4 2 41 F . D . &I. . S .

Washington 0 12 4 0 25 Twp. F.D.

Wayne 4 Tup F.D.

Williamsburg 0 55 5 4 58 Township F.D. U Withamsville 1 22 7 14 34 E.D.

Distribution of radiological monitoring equipment is given in Table G-5, Section II-G.

[)1)

TABLE III-B-4 Local Life Squads Resources Chart Life Squad Radios. Personnel Plectrons/

Pagers Mobile Portable Total (EMTs)

Bethel-Tate L.S. 20 1 24 Felicity-Franklin L.S. 20 1 28

!!onroe To.nship L.S. 28 30 Itoscow L.S. 10 1 23 flew Richmond L.S. 20 1 24 i.

f 8

APPLICANTS' TESTIMONY REGARDING CONTENTION 20.e.4 Contention i

Clermont County has only volunteer life squads in which only Goshen ;

and Miamiville have trained pa ramedics. The 119 life squad personnel within the plume area possess four mobile and no portable radios and ,

no information is provided as to vehicles or equipment possessed by the plume area life squads. The plan fails to establish how many, if -

any, of the plume life squads have certified emergency medical i 6

technicians on their staffs. The plan fails to indicate, with any reasonable assurance, or upon implementation, that any one, more, or ;

all of the volunteer life squad personnel would or could be present to assume any responsibility in the plume area during evacuation, or that

such personnel would or could leave their regular employment and *

, family responsibilities during evacuation. (Clermont Plan, III-B, !

Emergency Services, pp. III-B-4, 5 and 9.)

Testimony ll The Clermont County Radiological Emergency Response Plan provides for the effective response of life squads within the Plume -

Exposure EPZ to an emergency at ZPS-1.

r The five community life squads responding within the Plume '

Exposure EPZ will be providing normal emergency medical support as they would under all other circumstances. They a re Bethel-Tate, i Felicity-Franklin, Monroe Township, Moscow, and New Richmond. They [

each have one emergency vehicle equipped with a mobile radio. Under ;

most circumstances, the mobile radio is sufficient since communications rarely go beyond the emergency vehicle personnel and ,

the ambulance dispatcher. Since these squads will be providing normal l

emergency medical support, their current communications capabilities are adequate .fo r use during an emergency at ZPS-1. Additionally, a i new communications system is being purchased through the county life !

squads and Clermont Mercy Hospital using funds from a Federal grant.

b7

APPLICANTS' TESTIMONY REGARDING CONTENTION 20.e.5 ,

Contention The County Sheriff has 12 road patrol deputies. The local police have 14 full-time officers, with support from Pierce Township police in the ,

plume area, providing an additional nine full-time police officers.

The Ohio State Patrol has approximately 25 patrolmen at the Batavia ;

Post. In addition to the fo rego i ng , there are 16 volunteer police officers associated with the local police departments. At the time of i notification of an emergency mandating evacuation there would be approximately four deputy sheriffs, seven local policemen and eight ,

State Patrolmen on duty, for a total of 19 local police of ficers i available to provide emergency response resources to man access -

control points and direct traf fic and maintain order within the plume evacuation area. The Clermont Plan as drawn and to be implemented ,

provides no reasonable assu ra nce that local police are capable of ;

performing the response responsibility assigned, especially with the necessity to timely and safely di rect and control evacuation traffic.

Of f-du ty local police would be available on the ability to surmon such ,

officers to duty based upon the location of such of ficers and the '

presence of a point of notification contact. The plan presents no ,

reasonable assurance (nor can it be reasonably implemented) that there l is an ability to contact and summon off-duty local police officers to respond within th e time restrictions present to promptly and sa f ely direct the evacuation of the population. The time restrictions -

necessary to activate and deploy National Gua rdsman or to summon ,

police of ficers from contiguous counties provides no reasonable assu rance in the plan, or upon implementation, that such police and guard units can respond within time to sup) ort evacuation of the population. The number of local police of'icers and the limitation of police vehicles fails to provide any reasonable assurance that local [

police are capable of discharging the assigned responsibility. The number of access control points fo r the direction of evacuation ,

traffic is inadequate to properly, safely and timely direct the l evacuating population for the health and safety of that population, ;

together with the absence of any access control points manned by 3 police or other support emergency response personnel in the '

intersecting roads for travel by evacuees to evacuation ro u t es . ,

(Clermont Plan, II-I, Protective Response, pp. II-I-6, 15, 18, 23 and 24; III-B, Emergency Services, pp. III-B-1, 5 and 6.) 4 1

Testimony

, l The number of police officers in Clermont is adequate to carry ,

out their functions under the plan. The Clermont County plan as written allows fo r the establishment of. additional access control points as needed and provides for the personnel to man them.

l b9

VWe esea6XYWEment og access controX points GesHgnate@ in the plans is not intended as a prerequisite to proceed with an evacuation.

Indeed, an evacuation may be ordered before any access control points a re established. If established during an evacuation, access control serves to keep unauthorized persons outside of affected areas, and as a secondary benefit when possible, direct evacuees. Their primary function is controlling access into the affected area.

The protective action of access control, as emergency planning in gene ral, is based on the concept of a " tiered" emergency response.

It is a sequential supplementary response of the county, the State and the Federal Government, in that order. The Clermont County Sheriff, in coordination with the CCDSA Director and the County Engineer, will determine what access control points are to be established.

- Since local County resources and personnel a re located closest to the area affected by the emergency, the most immediate response fo r access control support is by the local Police Departments. Local Police Departments will provide manpower for access control support on local roadways in the County, at the direction of the County EOC.

These roadways include areas being evacuated and areas involved in take shelter ope rations. The Ohio State Patrol will support access control operations, on State and Federal highways. Their response will supplement local Police Department response, only when local resources are insufficient. The local Fire Departments may support local police and the State Highway Patrol, with access control, if their resources are needed. The Ohio National Gua rd will be ready to set up road blocks where needed, at the direction of the County EOC.,

if local resources are lacking. Federal assistance in support of access control will be by the U.S. Coast Guard. They will restrict or 60 i

cxcww p@gws of YWe dElo WYver to all commercial an6~ pleasure water t ra f fic if called for by local or State authorities.

The number of local full time police officers and Pierce Township full time police of fice rs stated in the contention is incorrect. The correct figures are:

Personnel Personnel Department (full /part time) (aux i l ia ry/vo luntec r)

1) . Clermont County 12/0 '

Sheriffs Department 2). Amelia P.D. 3/1 0 3). Batavia P.D. 5/0 0 4). Bethel P.D. 4/7 0 5). Felicity P.D. 1/2 0 6). Goshen Township P.D. 4/9 0 7). Loveland P.D. 9/6 0 8). Miami Township P.D. 13/4 0 9). Milford P.D. 10/0 0 10). Monroe Township P.D. 1/0 0 11). Moscow P.D. 2/0 0 12). New Richmond P.D. 5/0 2 13). Newtonsville P.D. 0/3 0 14). Owensville P.D. 3/2 0 15). Pierce Township P.D. 10/1 1 16). Union Township P.D. 18/0 0 17). Williamsburg P.D. 4/6 0 61

APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20.e.7, 20.e.10, 20.e.13 Contentions 20.e.7). The fire personnel, in part vo l un t ee r , in Campbell County are assigned the' task of fire response and, "if capable," to assist other emergency response functions without clarification. The plan provides no information as to either number of personnel and vehicles or support emergency functions. The plan fails to provide reasonable assurance that fire personnel are capable of discharging emergency response roles other than fi re rela ted activity. (Campbell Plan, Annex I, pp. I-1 and 2, I-1-2.)

i 20.e.10). The Fire Departments in Pendleton County are volunteer and i

are assigned only the duty of fire emergency. All contact with county fire units is by telephone and fire companies will be activated for fire; other functions to be coordinated at the time. The plan and its implementation fails to provide any reasonable assurance that the fire l companies will provide any reasonable assurance that the fire j companies will provide emergency response to protect the public in an !

evacuation. The plan presents no number of personnel or equipment available. {

(Pendleton Plan, Annex A, Direction & Control, p. A-9; l Annex I, Fire Protection / Rescue, pp. I-1 and 2, I-1-1.) j 20.e.13). Bracken County has four volunteer departments, trained in _

fire and rescue only. Departments have standby and call up procedures and other than fire related activity, the personnel are assigned access control functions during an evacuation. The plan and its implementation fails to provide any reasonable assurance that the personnel will provide emergency response for the protection of the public during emergency. The plan presents no number of personnel or equipment available.

Testimony The plan provision for the use of volunteer fire departments in Kentucky as emergency response personnel is adequate.

The fire departments will provide personnel for access control and verification of notification. These are functions that may normally be performed by fire department personnel during other types of emergencies. It is unreasonable to assume that they would be unable to perform these duties during a radiological emergency at Zimmer.

6*2

There is no MUREG-0654/ FEMA-REP-1 requirement for the listing of .

i i

emergency personnel, vehicles or equipment in the plan itself, i

! however, personnel and emergency vehicles are listed below.

r

Contrary to the assertion of contention 20.e.10, the Northern i

Pendleton Fire Department in Pendleton County can be notified by l

I

! pager, telephone, and two-way radio. Its personnel can be notified by i l

siren and/or monitor receivers. !

L t

Those fire departments and their resources within Cambpell, Pendleton, !

l and Bracken counties which could be used in response to an emergency (

f at Zimmer are listed below: i i ;

j i i

I. Campbell County Fire Department Resources l Fire Dept. Personnel Emergency Vehicles I t

- i Alexandria 75 1

Bellevue 40 4

4

-lr Camp Springs 30 5 Cold Springs 35 Dayton 2 (

35 5 !

Eastern Campbell 20 3 Ft. Thomas 6

(

4 Highland Heights 50 4

) Melbourne 30 4 Newport 47 7 f Silver Grove 20 5 l Southern Campbell 60 5 Southgate 70 2 Wilder 25 3 t I Woodlawn 20 1 !

L \

To ta ls 563 58 i

! II. Pendleton County Fire Department Resources j Fire Dept. Personnel Emergency Vehicles e

i Butler 20 4 Northern Pendleton 15 5 {

i i

Falmouth 37 5 !

} .

(

Totals 72 -

14 i j

i l

r I

63 I

_._ _ _ _ _ - _ _ . . . - _ - - - - - _. - _ , - - ~ . - - - - -- D

III. Bracken County Fire Department Resources Fire Dept. Personnel Emergency Vehicles Brooksville 25 8 Augusta 25 4 Totals 50 12 As the above figures indicate, Campbell, Pendleton and Bracken Counties have a ready resource of sufficient personnel and vehicles to assure an adequate emergency response. While the fire departments listed a re volunteer, there is every reason to assume that a sufficient number will respond during an emergency at Zimmer. The emergency plans also provide for the support of local response agencies by other local, state, and federal resources and agencies as necessary during an emergency.

61

. . _ ~ - _- - - - _. - _ - . _ _

APPLICANTS' TESTIMONY REGARDING CONTENTION 16 H ,

Contention 1

36 H) The Eastern Campbell County Volunteer Fire Depa rtment is i

located about one-fourth mile outside Mentor and serves Mentor as well t l

as an area in the southeast po rtion of Campbell County. The proposed ;

Campbell County plans call for i ts participation in an emergency :

i response (Annex F, Appendix F-6, p. F-6-1, Appendix F-9, III-C, p. F- [

9-3. Appendix F-10, III, p. F-10-1, Appendix F-11, II. p. F-11-1; ;

) Annex I, pp. I-1-1-2 Appendix I-1; and Annex M, I-B-2, p. M-1, and '

possibly IV-C, p. M-2, which refers to an Appendix I-2 which does not l exist). This fire department has no plans for a radiological l

l emergency response, has not participated in any state or local !

! planning effort, has had no training for fixed nuclear facilities [

radiological emergencies and does not anticipate such training, has ;

l inadequate or inappropriate radiological monitoring equipment, has no i radiological protective gear, and has no radio communications with the I Zimmer plant and inadequate radio communications with other state and :

local response agencies; and there is no evidence that the other fire ,

j departments within the 10-mile EPZ in Kentucky have adequate plans, j training, and equipment to respond to a radifological emergency. i Testimony >

The Campbell County Radiological Emergency Plan does include -

the Eastern Campbell County Fire Department as a response agency. Its i

responsibilities during a radiological emergency are described in the sections of the plan listed in the contention.

l The Fire Department does not have its own emergency plan since i its responsibilities a re included in the Campbell County Radiological t

[

Emergency Plan. This department has received a copy of the campbell !

4 4

County Radiological Emergency Plan and was encouraged by State and ,

i

local planning officials to comment on the Plan and express these l comments at a public meeting held August 27, 1981.

1 i

Training fo r this department and all other emergency response '

h a personnel is a currently ongoing process which will continue after the l

, commencement of commercial operation of Zimmer. Most fire department .

b i

nwsnor@ww wNaWip15Enr tounty wa6FlologKcaX Ismergency IPlan are similar to normal duties and additional training for these tasks is not necessary. However, training will be given to this department in accordance with the training schedule outlined in Annex S of the County Plan for those functions that are not exercised continually as l pa rt of their normal operations and for functions that are not 1

i specific to their normal operations.

l i

This Department is not required to perform any radiological monitoring f unctions and therefore has not been provided with monitoring equipment. However, the Department's personnel will be provided with personal dosimetry prior to entering a potential exposure area and will have been instructed on its use during the training sessions discussed above. Special radiological protective

, gear is not required for the tasks contemplated in the plan.

It is true that this Department does not have radio communications with the Zimmer Station and State agencies. They do, however, have. radio communications with other fire departments in the County and with the Campbell County Emergency Operations Center, from i

which its activities will be coordinated during the emergency.

The other fi re departments in the County will have similar training and responsibilitie.c.

k5kh

l l

APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20.e.8, 20.e.11, 20.e.la l

l Contention 20.e.8). Campbell County has no provision or information pertaining to rescue squads, except that rescue squads are present in the county l fire departments and possess ambulances. Fo fu rthe r information is l provided pertaining to training to treat radiological injury. The plan fails to provide reasonable assurance that emergency medical technicians are prepared to provide services other than first aid and hospital transportation and are not trained fo r th e identification and i segregation of radiation injury. (Campbell Plan, Annex H. Medical &

l Public Health, pp.H-2) 20.e.11). Pendleton has no provision or information pertaining to rescue squads except that such squads are present in the three volunteer fire departments and that they are trained in rescuing fire survivors. The plan as drafted and to be implemented provides no reasonable assurance that rescue personnel can determine and segregate radiological injured persons or to provide any emergency services.

(Pendleton Plan, Annex H, Health / Medical Services, pp. H-1 and 2; Annex I, Fire Protection / Rescue, pp. I-l and 2, I-1-1.)

20.e.14) Bracken County has no provision or information pertaining to rescue squads. The squads will provide ambulance service only. The plan as drafted and to be implemented provides no reasonable assurance -

that rescue personnel can determine and segregate radiological injuries or to provide any emergency service. (Bracken Plan, Annex H, Medical & Public Health, p. H-2; Annex I, Fire / Rescue Service, pp. I-l

, and 2, I-1-1.)

l l Testimony l

l The contention is based on a misinterpretation of the plan.

The plan provides for other personnel, not rescue squads, to examine, monitor, segregate, and decontaminate, if necessary, potentially contaminated individuals.

The plan provides for rescue squad personnel to transport those who cannot be decontaminated at decontamination centers and/or 1

are injured to the designated hospitals. Rescue squads usually have l at least one member who is an EMT (Emergency Medical Technician) trained in procedures to handle contaminated people.

67

prov fdes ~fo r t!h'e I'dentif fication of radiological

_. - _ _ _ . . . ~~ ~

exposed emergency workers and evacuees at designated decontamination and reception centers. Trained personnel will perform decontamination l as necessary. Those few individuals who may require additional

decontamination beyond that which can be provided at a decontamination i

i center will be treated at St. Luke Hospital or facilities in Lexington and Cincinnati.

1 During an emergency, County fi re depa rtments ' rescue squads

, a re the support agencies for emergency medical services. Gescue squad personnel administer fi rs t aid and prepare the injured for fu rthe r treatment. They also have ambulances and rescue vehicles to transport any ill or injured residents.

The State will support County rescue squad operations by p rov id ing , on request, Military Assistance to Safety and Traffic r

1 l

(MAST) and Kentucky National Guard Medevac equipment for transporting i .both contaminated and non-contaminated patients to medical facilities identified in the Kentucky Plan. The Kentucky State Police will provide personnel trained in first aid, and escort services and tra f fic control fo r rescue operations.

i

+

1 i

I 68

APPLICANTS' TESTIMONY REGARDING CONTENTIONS 20.e.9, 20.e.12 and 20.e.15 Contentions 20.e.9 The number of State and local police present and available to provide access control point manning and other traffic control direction to provide a reasonable assurance of a safe and timely evacuation of the population are inadequate in number, as well as an inadequate number of police to reasonably assure the safe and timely evacuation of A. J. Jolly State Park and Camp Sunshine. The plan fails to present any information pertaining to the number of police to be punctually available at the time of an evacuation, support police to be summoned, and the times required to afford supported police assuming duty stations or the number of police vehicles present and to be utilized in controlling evacuation. (Campbell Plan, Annex F, Protective Actions, p. F-9-2 and 3, F-1-1 and 2; Annex G, Law Enforcement, pp. G-1 G-2 and G-1-1, Annex K. Military Support, pp. K-1 and 2).

20.e.12 The number of State and local police and other resource support groups available to provide and man access control points and to provide traffic, together with providing traffic control and evacuation of Kincaid Lake State Park, is inadequate to present reasonable assurance by the plan or in its implementation that the population affected will be timely and safely evacuated from the exposed area. (Pendleton Plan, Annex F, Protective -

Actions, pp. F-9-2; F-10-1; Annex G, Law Enforcement, pp. G-1 and 2, G-1-1.)

20.e.15 The number of local police and other resource support groups present to provide and man access control points and to provide traffic control is inadequate to present reasonable assurance by the plan or in its implementation that the population affected will be timely and safely evacuated. (Bracken Plan, Annex F, Protective Actions, p. F-10-1; Annex G, Security and Law Enforcement, pp. G-1 and 2, G-1-1.)

Testimony Emergency planning for the Zimmer Station is based on the concept of a " tiered" emergency response. This concept involves planning for an emergency through the sequential supplementary response of the Zimmer Station, the l County, the State and finally the Federal government in that order.

Since county resources and personnel are located closest to the area affected by the emergency, the most inmediate response is by the counties.

State response will supplement the response by counties only when county resources are insufficient. The Federal Government will also make available, e

l at State request, its extensive resources and expertise through the Federal Radiological Monitoring and Assessment Plan, its interagency radiological emergency response organization. In an emergency situation, local agencies t

will usually respond first due to their relatively rapid mobilization time and short travel time. State and Federal agencies have specialized resources for responding to a radiological emergency. These resources can be activated and mobilized when needed. Concurrent with the response of local agencies to an emergency situation, appropriate State and Federal agencies are notified of the situation and preparations are made for a possible response to the emergency situation. This approach allows State and Federal agencies to monitor the evolving emergency situation and to respond in a minimum amount of time, if needed.

The concept of a tiered emergency response can be demonstrated by examining -

how access control is accomplished. Local police departments have the primary responsibility for manning access control points. If additional assistance is required, local fire departments or neighboring police departments can provide support. If further assistance is needed, the State Police and the National Guard can be utilized. Local manpower constitutes one tier of emergency response support, while state manpower constitutes the second tier of emergency response support. This approach ensures that sufficient manpower will be available to provide an adequate emergency response support.

The concept of a tiered emergency response is set forth in NUREG-0654.

NUREG-0654 states that the concept of emergency planning zones implies mutually supportive emergency planning and preparedness arrangements by several levels

! 70

1 of government: Federal, State and local governments, including counties, townships and even villages.

1 The plans are adequate since sufficient County and State manpower and vehicles are available to assure a safe and timely evacuation of Campbell l County, Pendleton County, and Bracken County, including A.J. Jolly State Park, Camp Sunshine and Kincaid Lake State Park.

The establishment of access control points designated in the plans is not intended as a prerequisite to prcceed with an evacuation. Indeed, an evacuation may be ordered before any access control points are established.

If established during an evacuation, access control serves to keep unauthorized persons outside of affected areas, and as a secondary benefit when possible, direct evacuees. Their primary function is controlling access into the affected. _

area. Access control points are established as soon a5 possible once an evacuation or shelter order is provided and maintained even after an evacuation until general reentry is accomplished. The source of personnel used to maintain

, these points may change as the extent and nature of an emergency'becomes l apparent.

In the event that an evacuation of a portion or all of the plume exposure EPZ within Campbell County is required, local law enforcement agencies will begin to establish and maintain selected predetermined access and traffic control points. Local police and fire departments have the primary responsibility for implementing access control measures and will be assisted by Northern Kentucky University Security personnel. The Campbell Plan, Annex G, Law Enforcement, pg. G-1-1 lists 14 Campbell County police departments that can be utilized for access control. If additional access and traffic control j

! 71

._ _ _~- - . - - , - _ _ _ . _ _ . _ ~ , _ _ , _ _ - _ _ . . _ . . _ . _ , _ _ _ _ _ _ . - . _ . _ , _ _ _ _ _ . - . _ _ .

- - -- - =. .

support is required, the County will be assisted by State police and the Kentucky National Guard (Campbell Plan, Annex G, Law Enforcement, pg. G-2).

The Campbell County Judge / Executive can also request support from the Kenton County Law Enforcement agencies to support access control (Campbell Plan,

] Annex F, Protective Actions, Appendix F-10, pg. F-10-2).

Evacuation of the A.J. Jolly State Park and Camp Sunshine does not directly involve the use of state or local police. The siren /public address a

system located in the Campbell County Park will alert transients to take protective actions. In the event of an evacuation of Camp Sunshine, camp personnel who have private vehicles will be used for evacuation. (Annex F, Protective Actions, pg. F-9-3). If additional transportation resources are required, Camp Sunshine residents will proceed to the Eastern Campbell County Fire Department for pickup and will be transported by County resources, -

including possibly County and State police.

In the event of an evacuation of a portion or all of the plume exposure EPZ within Pendleton County, local law enforcement agencies and fire departments will establish and maintain selected access and traffic control points (Pendleton Plan, Annex F, Appendix F-10, pg. F-10-1). The Pendleton County Sherriff's Department, the Falmouth Police Department and the Butler Police Department have the primary responsibility for implementing access control measures (Pendleton Plan, Annex G, pg. G-1-1). If additional access and traffic control support is required, the county will be assisted by the State Police and the Kentucky National Guard (Pendleton Plan, Annex F, Appendix F-10, pg.

F-10-1).

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Evacuation of Kincaid Lake State Park does not- directly involve the ;

use of State or local police. The siren /public address system located in ,

the park will alert transients to take protective actions.

Few or none of i

the transients would be expected to need transportation assistance since the park is accessible only by private transportation. If needed, additional 4

i access control assistance can be provided by County and State police. !

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1' i In the event of an evacuation of a portion or all of the plume exposure EPZ within Bracken County, local law enforcenent agencies and fire departments j

will establish and maintain selected predetermined access control points. !

The Brooksville Sheriff's Office, the Brooksville Police and Fire Department !

will man these access control points (Bracken Plan, Annex F, Appendix F-10, pg. F-10-1). If additional access and traffic control support is required,

_i the county will be assisted by the State Police, the Kentucky National Guard l

and the Germantown Police Department (Bracken Plan, Annex G, pg. G-1 and ,

2,G-1-1). !

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APPLICANTS' TESTIMONY REGARDING CONTENTION 20 f 1 Contention 20 f 1) At flood stage, Ohio River crest of 53 feet, U.S. 52, approximately 1/4th of a mile north of the Village of Neville is under water and impassable as to U.S. 52, Neville Spur and Maple Creek Road for an approximate distance of 1/2 mile and including Maple Creek. 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 1/2 mile and including Ray Run. On either side of U.S. 52 at the intersection of Laurel-Moscow Road for a distance of approximate 1/2 mile, U.S. 52 is under water and impassable and at a 64-foot Ohio River crest the bridge over Little Indian Creek near Laurel-Moscow Road-U.S. 52 intersection, on U.S. 52 is under water and impassable. U.S.

52 at the Village of Point Pleasant, including the intersection of U.S. 52-Indian Road, intersection of U.S. 52 and S.R. 232, for an approximate distance of 1/2 mile is under water and impassable. From, and including, Clermontville Road, and its intersection of U.S. 52, portions of Clermontville Road and approximately 1/2 mile to the north, U.S. 52 is under water and impassable.

From a distance of approximately 1/4 mile south of the Village of New Richmond to approximately 1/4 mile south of the intersection of Bethel-New Richmond Road and U.S. 52, U.S. 52 is under water and impassable. Within two hundred yards of U.S. 52 and to the west of U.S. 52, the streets of the Village of New Richmond are under water and impassable. The bridge located on Fagins ~

Run Road within 50 feed of S.R.132 is under water and impassable due to the flooding of Twelve Mile Creek and that evacuation route entry into S.R.

132 for the population northeast of the location is closed. Flooding of the Ohio River at a crest of 80 feet (1937 flood) U.S. 52 is under water and impassable from approximately 1 mile east of the Village of Neville to the west and north to within approximately 200 feet of the entrance to 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 eid to the northwest of New Richmond, U.S. 52 is under water and impassable.

Maple Creek Road, S.R. 743, Laurel-Moscow Road, Indian Road, S.R. 232 Clermontville Altman Road, and Frank Willis Memorial Road are all under water and impassable at their respective intersections with U.S. 52, totally precluding vehicular travel to the Zimmer Station. During flood crests of the Ohio River from 53 feet to 80 feet a range from a substantial portion of an evacuation route is impassable and vehicular travel to the Zimmer Station is limited to S.R.

743 to U.S 52 to Zimmer to the exclusion of U.S. 52 as an evacuation route from New Richmond to beyond Neville and the isolation of the Zimmer Station.

Under those circumstances, including flooding of the Zimer E0F site, evacuation and emergency plans cannot be implemented. (No plan provision).

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Testimony

< The Clermont County Plan provides for other alternative protective actions. An evacuation is not called for in every emergency.

t Residents are aware of alternate available routes should localized l flooding occur. In tne event of major flooding of the Ohio River, most if not all of the population in those affected areas will have been previously

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evacuated or will be aware of passable egress routes from their home.

The Zimmer EOF in Moscow is a temporary location scheduled to be replaced by a permanent E0F in Batavia, Ohio in accordance with NRC requirements by the time Zimmer begins commercial energy production. Batavia will not be affected by flooding of the Ohio River. Thus, implementation of emergency ,

plans will not be affected.

Zimmer will stop commercial power producticn if the Ohio floods at 75 feet or above, significantly reducing the possibility of an evacuation

being called under these extremely adverse conditions. Access to the Zimmer Station during a flood is assured via the high level access road which does not depend on the utilization of U.S. 52. .

See also Testimony regarding Contention 20 g 1.

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j APPLICANTS' TESTIMONY REGARDING CONTENTION 20 g 1

, Contention 20 g) During inclement winter weather conditions, roadways in the involved counties of Ohio and Kentucky are impassable due to accumulations of ice and snow, rendering evacuation of the respective populations and response of offsite emergency units to the Zimer Station impossible for substantial time periods, and the majority of access roadways for evacuation purposes remain impassable for prolonged periods of times, measured in weeks, thereby prohibiting large segments of the Emergency Planning Zone populations of the involved counties from being evacuated promptly and timely by other means; and a large segment of the Emergency Planning Zone populations of the involved counties are unable to reach access roadways from their residences for extended time periods daring the presence and continuation of large accumulations of snow, thereby precluding either their evacuation by motor vehicle or the j timely and prompt evacuation by other means.

Specifically.

20 g 1) The Ohio roadways set forth in Contention 20 c) 1), 2) and 3) and the Kentucky roadways set forth in Contention 20 c) 7), 8),11),

and 13) are rendered impassable due to ice and snow accumulations during the period December 1 to March 31 annually. The roadway crews available in each of the respective counties are not equipped to rapidly remove snow -

and to sand and salt to render the roadways passable. The federal and state highways in the respectively counties remain impassable for periods of approximately three hours to 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months . County and township roadways cannot be made passable from periods ranging for two to 14 days. The topography and land characteristics, together with the roadways being hilly, narrow, steep and winding, precludes any vehicle travel, other than four wheel drive vehicles. Police vehicles

'i were rendered useless during the winters of 1977 and 1978 and police activity was limited to one four-wheel vehicle in Clermont County and volunteer four-wheel drive operators to transport necessities to families that could not leave their residences. A majority of the population of the involved counties maintain their residences approximately 100 to 700 feet from the public roadway and vehicles at the home are inoperative and transportation by vehicle is capable only at the intersection of the residence lane with the public roadway.

An evacuation during snow or ice accumulation, rendering a portion or all of the evacuation routes impassable and rendering the service roadways of township and county roadways for travel to evacuation routes impassable would result in the inability to evacuate the affected population due to impassable roadways and the absence of sufficient support vehicles present to evacuate.

No county possesses sufficient snow moving, salting and sanding equipment :

and personnel to maintain roadways passable during snow and ice accumulation to present reasonable assurance that the population can evacuate during this seasonable condition. (No plan provision).

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Testimony I An actual or potential radioactive release from ZPS-1 may make 1 i it necessary that protective actions be taken to safeguard the health and

! welfare of the population of the Plume Exposure Pathway EPZ. When protective I actions are being considered, the risks involved in taking the protective action must be weighed against the potential radiation dose savings due to i the protective actions. Evacuation is only one of the possible protective actions available to public officials for recommendation te the general public.

{ Protective actions in addition to evacuation are set forth in Annex i

l F of the Kentucky Radiological Emergency Plan and Section II-I of the Clermont County Radiological Emergency Response Plan. Other protective actions that may be considered include in-place protection / sheltering with access control.

Due to the possible hazzards associated with relocating a portion of the

population, in-place protection / sheltering may be the preferred protective

.I action to follow during extreme snow or ice conditions.

All affected roadways in the Plume Exposure EPZ are not likely

.! to be impassible during the winter months. Roadway crews are available to i

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remove snow and to sand and salt. If it is deemed essential to evacuate any portion of the population within the Plume Exposure EPZ during inclement weather conditions, traffic controls can be established to direct the flow i of traffic along the safest possible routes to the relocation centers. Traffic controls are to be distinguished from access control points which serve mainly to control entry into the area being evacuated or sheltered. Based on information regarding weather and road conditions, Kentucky and Clermont County officials i may provide traffic control points in locations that will assist the population

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in evacuating the affected areas.

See also Testimony regarding Contentions 20 c 6, 10, 12, 14.

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! APPLICANTS' TESTIMONY REGARDING 1 CONTENTION 21 Contention

21. The evacuation plans for the plume exposure pathway of the j Emergency Planning Zone includes 18 elementary and secondary schools situated

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in Clermont County, Ohio and Bracken County, Pendleton County and Campbell County, Kentucky. Evacuation plans for these schools are inadequate to evacuate

, the populations of such schools in a time period required to reduce, or minimize, ,

i exposure and protect the safety and health of the children.

Response

1 Within the plume exposure pathway of ZPS-1, twenty-one schools are located in six school districts. The locaticas of these schools range from t

j 3.5 to more than 10.5 miles from the plant as the following summary indicates:

! 1. A. J. Jolly Elementary (Campbell County) 3.5 miles l 2. St. Peter & Paul Elementary (Campbell County) 4.5 miles -

3. Monroe Elementary (Clermont County) 5.0 miles j 4-6. New Richmond Elementary, Junior j and High Schools (Clermont County) 6.8 miles

) 7-9. Felicity-Franklin Elementary, Junior and High Schools (Clermont County) 7.5 miles

] 10. Northern Elementary (Pendleton County) 8.5 miles

11. Grants Lick Elementary (Campbell County) 9.0 miles l 12. Southern Campbell County Middle School i (Campbell County) 9.0 miles i

13. Western Hills Elementary (Bracken County) 10.5+ miles i

14-15. Alexandria Elementary and High Schools j

(Campbell County) 10.5+ miles

] 16. St. Mary Elementary (Campbell County) 10.5+ miles l

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17. Bishop Brossart (Campbell County) 10.5+ miles

18. Campbell County Vocational School (Campbell County) 10.5+ miles 19-21. Bethel-Tate Elementary, Middle and 4

High Schools (Clermont County) 10.6+ miles 4

Thus of 21 schools within the plume EPZ 8 are 10 or more miles from Zimmer with another 2 being 9 or more miles away. The eight schools which are located more than ten miles from ZPS-1 have been included in the plume exposure EPZ by local officials for planning purposes. While the plans call for evacuation of all schools as quickly as possible, it is the intention of public officials to direct resources towards the closer schools first.

Each of the affected schools has or will have a set of school protective .

action procedures to implement the concepts contained in the various emergency plans in the event of an emergency. The Clermont, Pendleton and Bracken Counties procedures are nearing completion and the Campbell County procedures are under development.

i In the event of an emergency, the school superintendents may be notified by pager, tone-activated NOAA radio, monitor radio and/or telephone call 4

from the appropriate Emergency Operations Center (E0C) personnel. In Clermont County, the Board of Education Superintendent is a member of the EOC staff and will establish communications with the affected school districts from this post. In Kentucky, the school superintendents will communicate with the affected schools from their offices or homes depending on the circumstances of the emergency. The school district superintendents direct the resources of their district and maintain communication with the schools and E0C. The actual implementation 93 1 _ .- - -

of protective action at the schools is directed by the principals.

The primary means of communication with the schools will be by telephone.

Some of the schools, are located on a common site such as those in Alexandria and New Richmond. Communication at these schools complexes can be facilitated by the use of a messenger, if necessary, thereby easing the demands on the telephone system.

Evacuation of the general public, including school children, may be chosen as the best protective action only after full consideration of the particular

, emergency situation. The evacuation time estimate for the geographical area under consideration, the weather conditions, the time of day and the availability of school buses and drivers all have weight in the decision process. Should any of these factors render evacuation unwise, the most likely protective action _

is sheltering.

Additionally, the schools may be closed as a precautionary measure upon the county's recommendation to the school superintendent before any other offsite response is required. Again, the discretion of county officials in respone to the circumstances of the emergency will determine the appropriate action to be implemented.

An evacuation of school children will be accomplished using the available county school buses and special buses for the handicapped. New Richmond and Bethel-Tate school districts have obtained agreements from West Clermont and Clermont Northeastern school districts for the use of additional buses. Campbell County has obtained a similar agreement, for the use of ten TANK (Transit Authority I

of Northern Kentucky) buses. Those schools nearest to Zimmer will receive I the needed vehicles first resulting in minimum evacuation times.

4 60

Bus driver notification will be accomplished by telephone or the Prompt Notification System. In the unlikely event that county officials chose to initiate an evacuation when the buses are routing, the bus drivers will complete their routes for reasons of student safety and accountability. Upon reaching -

the schools or garage, the bus drivers will receive further instructions from school officials who are in communication with the energency response officials.

The evacuation of handicapped students will be generally accomplished with county lift buses. Privately owned vehicles, as well as the fire department, may supplement this, if necessary.

See also response to Contentions 20.b.5 and 20.b.6.

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APPLICAf4TS' TESTIMONY REGARDING CONTENTIONS 21.b.2, 24.5 24.8 and 36F Contention 21.b.2 Ohio has employed the pclicy that it will administer potassium iodide to emergency workers only and not to the general public. Ohio has made no provision whatsoever to administer potassium iodide to the sensitive and vulnerable group, the child. Ohio will not monitor children or adult for a maximum period of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months at reception site to determine whether such individuals have been contaminated, a period too long to protect the health and safety of the public, especially the child, and at that delayed period (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) the administration of potassium iodide would be of little effect.

Kentucky will administer potassium iodide to emergency workers and to the general public, including children. The Kentucky plan has no provision for the implementation of the administration of potassium iodide and, unless administered early, its effect is diminished. No plan provides for the timely administration of potassium iodide to school children. The plan as drafted and to be implemented provides no reasonable assurance for the timely administration of potassium iodide to school children by school personnel or other emergency resource workers and as such there is no reasonable assurance that the safety and health of children will be protected in the event of contamination.

(Ohio Plan,Section III, Letters of Agreement, Letter 14; Clermont Plan, Section II-B, Emergency Response Support, p. II-B-1 (no plan provision); -

Campbell Plan, Basic Plan, V-8, Annex F, Protective Actions, p. 7, F-11-1; Pendleton and Bracken Plans comparable to Campbell Plan.)

24.5 Ohio applies the policy that it will not administer potassium iodide to the general public, including children. This position, taken by the State of Ohio and its political subdivisions of Clermont County, removes any consideration of a reasonable assurance being presented by state and county plans and the failure to implement any procedure f.- the prompt administration of potassium iodide to block radioactive iodine intake to the thyroid gland, and presents a substantial departure from required protective action to safeguard the health and safety of the exposed population. (Ohio Plan,Section III, Letters of Agreement, letter 14; Clermont Plan, Section II-8, Emergency Response Support, p. II-B-1 (no plan provision).

24.8 Campbell County provides no plan or its implementation for the timely administration of potassium iodide as to the manner, place, administration and timely presentation of such blocking agent to the general public, and as such there is no reasonable assurance that the blocking agent can be systematically and timely administered to the public. (Campbell Plan, Basic Plan, p. V-2; otherwise no plan provision.)

36F Although the plans acknowledge that it is important that potassium iodide (KI) be adminstered as early as possible after a radioactive release and that it loses effectiveness quickly over a short period of time, there are no plans for the storage or distribution in Mentor or in the innediate vicinity of Mentor or within the 10-mile EPZ of KI for use by the general public (Campbell County plan: Annex F, IV-A-3, p. F-4, IV-F, p. F-7; Appendix F-11.)

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Response

Neither Nuclear Regulatory Commission regulations nor NUREG-0654 i require agencies to administer potassium iodide. NUREG-0654 only requires that agencies identify their plans, or intentions, regarding potassium iodide l administration. The emergency plans identify the agencies' intentions with respect to potassium iodide.

The Ohio Director of Health has stated that, as a result of consultation i i

with numerous experts, the Ohio Department of Health will not provide potassium iodide for emergency workers or residents at this time. The reasons he gave I are: "While some states have included plans for the distribution of potassium iodide in their emergency plans, many have not. Due to the lack of nationally .

recognized guidance and after consideration of the many adverse factors at

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risk, it is my professional opinion that it would not be in the overall best interests of the citizens of Ohio to provide potassium iodide at this time." ~

(Letter 14 in Letters of Agreement,Section III, Ohio State Plan).

6 l The Campbell County radiological emergency plan states that "...it 1

i q 1s important that potassium iodide (r(I) be administered as early'as possible '

l subsequent to the release of radiciodine" (not a radioactive release). )

i (Reference Annex F protective actions page F-7). The Campbell County Plan also states in Appendix F-11, page F-11-1 that:

" potassium iodide for use by the general public will, ;

in accordance with State policy, be stored at a convenient '

medical facility within Campbell County as well as in ;

Bracken and Pendleton Couaties. From here, potassium

iodide will be distributed as necessary. Detailed potassium iodide distribution plans are currently being prepared ;

by Kentucky Disaster and Emergency Services and the County l Disaster and Emergency Services organizations and will i

be complete prior to cormiercial operation of the ZPS- ~

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1. The Radiation Control Branch and the Bureau for Health !

Services will be responsible for maintaining and coordinating the periodic replacement of potassium iodide supplies ,

intended for use by emergency workers and the general i public." !

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. l Therefore, the statements that the plan provides no pre /ision for timely administration of potassium iodide are not true.

1 Thyroid uptake is a condition in which the thyroid gland holds radioactive iodine. Potassium iodide reduces radiation dose to the thyroid gland by blocking

! (saturating) the gland with non-radioactive iodine, so that when the radioactive l

1 iodine arrives at the gland it is not absorbed. Potassium iodide does not, however, significantly reduce whole body exposure.

l In regard to the contention that a maximum period of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months before i

monitoring is too long of a period for the administration of potassium iodide to be effective, this statement is an incorrect interpretation of NUREG-0654 l

l provisions concerning monitoring of evacuees. NUREG-0654 states that " personnel ,

and equipment available shall be capable of monitoring within about a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months i

period all residents and transients in the plume exposure emergency planning i

zone arriving at relocation centers." This provision is not intended as an evaluation criteria for the use of potassium iodide. The administration of potassium iodide is not dependent on the results of evacuee monitoring since it must be taken prior to or as early as possible after inhalation of radioiodines to be effective. Personnel contamination itself is not expected to result in a significant radiation dose to anyone. Therefore, the time between contamination and decontamination is not critical. The plans provide for monitoring and, if necessary, decontamination as soon as possible after arrival at the decontamination stations.

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4 APPLICANTS' TESTIMONY REGARDING CONTENTION 21.c.1 Contention 21.c.1 The New Richmond School District has 17 buses and a student population of 2,562 students. The schools located in this district are at three different sites. The current fleet of buses requires that the student population being bused to or from school by each bus traveling three routes for each transportation of students, requiring that the bus be in transit for one hour each morning and evening routes. Monroe and Pierce Elementary students would be evacuated to the receiving site first and then return of buses for evacuation of the student population at the New Richmond site. From boarding of buses to the receiving site at Glen Este and return would consume approximately

, one hour before commencement of the boarding of the New Richmond school population.

Total evacuation time for the last students to be evacuated and out of the

10-mile zone would be approximately four hours. The number of buses necessary to timely and promptly evacuate the New Richmond District school population would be 43 buses. New Richmond is 26 buses short of the required number to evacuate effectively the school children of this district. The plan as implemented has no assurance, reasonable or otherwise, that school children can be effectively evacuated in a safe and timely manner.

Testimony The Clermont County Plan provides reasonable assurance that the plume exposure zone school population ~of the New Richmond District can be evacuated in a safe and timely manner. Pierce Elementary School, although part of the New Richmond School District, is not within the plume exposure zone. The district has only 2200 students in four schools within the 10 mile EPZ and about 10%

less, or 2000 students, are generally in attendance. (Additional students attend Grant Joint Vocational School, which is also outside the EPZ.) Three f

of the schools within the EPZ are in the town of New Richmond, approximately 7 miles from the Zimmer Plant. The fourth school, Monroe Elementary School, is 5.0 miles from the plant. The district has 22 buses in operating condition, each capable of carrying 60 students. The West Clermont District has agreed l

to send 17 additional buses, of similar capacity, immediately upon request from the New Richmond Superintendent, to assist in the evacuation of the New l Richmond School population.

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The total seating capability is therefore 2340, sufficient for the 2000 students to be evacuated. In this way, sufficient buses will be available to assure that the entire New Richmond student population within the plume exposure EPZ is promptly evacuated and that students in the three New Richmond Schools will not have to wait to be evacuated until buses return from evacuating the Monrce School. There has been no account taken of the number of students that can be evacuated by school staff vehicles and student cars.

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APPLICANTS' TESTIMONY REGARDING l CONTENTION 21.c.2 Contention

' Bethel-Tate School District has 12 buses e,d a student population of 1900. The schools within the district are located at one site. The current fleet of buses requires that each bus transport students on two trips, morning !

and afternoon. Approximately one-half of the student population would be evacuated {

to Goshen schools and bus return before the remaining population could be bused.

The total time for evacuation would be approximately three hours. The number j

of buses necessary to evacuate the student population of this district would be 31 buses. Bethel-Tate is 19 buses short of the required number to effectively [

' evacuate the school children of this district. The plan as implemented has !

no assurance, reasonable or otherwise, that school children can be effectively t

, evacuated in a safe and timely manner. I l Response l The Clermont County Plan provides reasonable assurance that Bethel-Tate school children can be evacuated in a safe and timely manner. '

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The Clermont Northeastern School District which is located outside the plume EPZ has agreed to supply the Bethel-Tate District with the additional I I

buses needed to evacuate the entire Bethel-Tate school population in one !

Clermont Northeastern buses will be dispatched to the Bethel-Tate trip.

Schools upon receiving a request from the Bethel-Tate Superintendent. If j already in use, these buses would be dispatched upon returning to their schools.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 21 c 3 Contention Buses sent from other districts can not timely evacuate the children at the two involved Ohio school districts because of the time requirements for transportation of those buses from original site to the plume school site and the circumstances of the necessity to utilize those buses for the evacuation of the students located at the receiving sites to afford reception of the evacuees, adult and school child. [tka plan provision, Ohio or Clermont Plans; see limited discussion, Clermont Plan, II-I, Protective Response, p. II-I-5; III-A, County Agencies (Gen), p.

III-A-2, III-C, County School Districts, pp. III-C-1 through 3 and 5].

Testimony The Clermont County Plan provides reasonable assurance that the school children of the Bethel-Tate and New Richmond .

districts can be evacuated in a safe and timely manner. l Upon request from the Bethel-Tate School Superintendent, the Clermont Northeastern District which is outside the plume EPZ will dispatch the required number of additional buses to support evacuation of the Bethel-Tate School population. It is not necessary to dismiss students from reception center schools in advance of transporting evacuated students to these schools.

Clermont Northeastern buses will be dispatched to Bethel before they are used to transport the Clermont Northeastern student population to their homes. The distance these buses will have to travel, from the Batavia-Owensville area, where they originate, to Bethel, is approximately 10-15 road miles, and will not create a delay in getting the Bethel school evacuation underway.

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A similar procedure has been developed for the New Richmond District, with additional buses being supplied from the West Clermont District, which is approximately the same distance from the New Richmond Schools as is Clerraont Northeastern f rom Bethel-Tate Schools.

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APPLICANTS' TESTIMONY REGARDING CONTENTIONS 21 c 4, 21 d 4 and 36E Contentions 21 c 4]. The Campbell County School District has nine schools at various sites, including A. J. Jolly Elementary approximately two miles f rom the Zimmer Station. It has 60 buses, 25 of which are eight years or older and subject to mechanical failure, and a student population of 6,111 students.

Students are transported to and from school in morning and evening double and triple routing. More than half of the student population would be required to remain at school while the first evacuees would be transported to a reception site and the buses returned to the schools to continue evacuation.

Sixty-two additional buses would be required to provide timely safe evacuation of the students in the affected area. In addition to the aforestated buses, the district is required to utilize two lift buses for handicapped children, each bus required to make two trips. No other buses would be available of any type to accommodate the evacuation of the handicapped children in a timely and safe manner. The time required to evacuate the studen: population would be approximately five hours. The plan as implemented has no assurance, reasonable or otherwise, that school children can be effectively evacuated in a safe and timely manner. (Campbell Plan, Basic Plan , pp. II-4, 7 and 8, V- 5, 6 and 11; Annex C, Notification and Warning, p.

C-4 Annex F, Protective Actions, p. F-9-2.)

21 d 4]. The evacuation times set forth in the specified paragraphs of Contention 21 c would be substantially increased and for which there is no plan or its implementation capable of presenting an assurance, reasonable or otherwise, that the affected school children could be timely and safely evacuated from the affected schools. (No plan provision.)

36E]. The several schools, public and private, located within the 10-mile EPZ in Kentucky lack suf ficient buses and drivers to evacuate the school children in a fast, safe and orderly manner; the buses do not have communications equipment for use during an evacuation or for notification and instruc-tions to drivers in the event of a radiological emergency during the picking up or delivering of school children to and from schools or during the use of buses in school activities; there is no radio communications system for warning (first alert) or for use during an evacuation between the schools and the Zimmer Pla n t , and the various local, state and federal response agen-cies; there is no internal telephone system of dedicated lines 6e v between the central office and several schools; and there is no agreement between the local boards of education and the state and local radiological response planners and agencies that the 90

i schools or the response agencies have the procedures, equipment or manpower to ensure a f ast, safe and orderly evacuation of school children.

The Kentucky Division of Disaster and Emergency Services has publicly stated that neither it nor its Campbell County counter-part has written or will write SOPS for the schools, but that it

is the schools' responsibility to write them. There is no evi-dence that SOPS for schools have been written or will be written in the foreseeable future.

Despite the fact that the Campbell County school system does not have enough buses to evacuate school children simultaneously (it daily uses 54 buses to accommodate 5800 children and about half of the buses are involved in shuttle, double, or triple runs),

the proposed Campbell County plan says that the school system is the " primary agency for transportation" during an evacuation

( Annex M, IV-A, p. M-2) and assigns the system the additional duty of patroling the 10-mile EPZ and providing evacuation transportation for people without personal vehicles.

(Campbell County plan: Annex C, IV-D-1, p. C-4; Appendix F-6; Appendix F-9, II, p. F-9-1; Apendix F-9, III-A p. F-9-2; Appendix F-18, pp. 3-4 p. 3-2, pp. 4-1 and 4-2 p. 5-6).

Testimony -

The Campbell, Pendleton, and Bracken Counties Plans provide for the effective evacuation of school children in a safe and timely manner.

The affected schools in Pendleton and Bracken Counties can be evacuated using their existing resources. The Campbell i

County schools will be evacuated using the 60 county school buses (including two lift buses for handicapped). The plan also provides for the supplemental use of ten TANK buses. It is expected that the four Campbell County schools actually within 10 miles of Zimmer can be readily evacuated first without any double routing. There are only 1,136 students in these four schools. The remaining five county schools within the EPZ, but 31

outside 10 miles, will be evacuated next and, if all buses are l

available, no double routing would be required for evacuation of i

these schools.

The evacuation of handicapped children attending Campbell County Schools will be accomplished with two county lift buses supplemented by privately owned vehicles present on school lots 4

and the fire departments, if necessary.

The Campbell County School Protective Action Procedures were initiated at a meeting on December 2, 1981 attended by Kentucky DES, Campbell County DES, S&W and Campbell County school officials. It was agreed that for the sake of accounta-bility and student safety, buses will complete their routes if an emergency should occur during morning or af ternoon routing. _

4 The drivers will then receive further instructions upon their return to the schools or garage.

f Several alternative means exist for notification of bus drivers, in addition to the normal means of a telephone call from the School District Superintendent. Bus drivers within the l plume exposure EPZ, as part of the general public, could hear of an emergency through the Prompt Notification System, consisting of sirens and NOAA tone alert radios. During school hours they would then proceed to the schools and receive further instructions. Those drivers living outside the EPZ and who are not at home during the emergency may receive notification over l

! one of the EBS radio or television stations. Procedures are I

being developed whereby the Superintendent of the Campbell County Schools will call the Greater Cincinnati Broadcasters Association to make appropriate announcements, lYd

1 l

l The decision to evacuate the schools will be made l considering the availability of school buses, bus drivers, and other specifics of the emergency at hand. Other protective actions are possible and may be implemented as circumstances and 1

resource availability warrant. Resources will consequently be directed, depending on emergency circuustances, to those schools l

closest to Zimmer resulting in minimum evacuation times.

l School bus assistance in evacuating the public without pri-l vate vehicles after having evacuated the school children is 1

l addressed in the response to Contention 20 e 9.

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APPLICANTS' TESTIMONY REGARDING CONTENTIONS 21 d, 21 d 1, 21 d 2, and 21 d 3 Contention 21 d]. The respective school districts do not possess either the capability or the number of buses necessary to af ford transportation for the evacuation of school children where the emergency evacuation arises during bus transportation of chil-dren for the commencement or termination of the school day, because of the bus routing, multiple routes and trips, and a portion of the children being located at the school site and the remaining children being transported in the available buses.

Specifically 21 d 1]. The schools involved in the New Richmond and Bethel-Tate School Districts of Ohio and the Campbell County School District of Kentucky have no means of communication to bus drivers while the driver is enroute. No present state or county plan presents a reasonable assurance or could be capable of implementation where students have been received at each school site following the first route trip and while the buses and drivers are in the course of picking up students preparatory _

to transporting them to school and evacuation is ordered and there is no present ability to contact the drivers and to direct '

them to transport the students currently on the buses to a receiving or other site, during which time the driver would continue on his normal route and there would be no provision for the summoning of those buses to transport the students required to be evacuated to a receiving site.

1 1 21 d 2]. No other school district contiguous to the involved school districts could dispatch buses to the three af fected districts because of utilization of their respective fleet of buses and the inability to communicate with their j drivers to advise discharge of their passengers.

21 d 3]. The converse of 1) and 2) would apply during the af ternoon initial routings, where a portion of the student popu-lation would be on buses and the remaining student population at school without bus facility.

Testimony The particular scenario described in Contention 21 d 1, above presents no special obstacle in executing an effective evacuation because typical bus routes in the three schools districts are normally driven in periods of time less than the 91

assumed period of time required for mobilization (i.e., prepara-tion) of public following initial notification. Therefore, should the unlikely situation develop such that the Clerront i County DSA Director or the Campbell County DES Director chose to initiate the evacuation of school children while school buses were in transit to the school with children, and the buses

, were to continue boarding school children and deliver them to the school, the bus driver would then be directed by school 3

officials to drive the students to the appropriate relocation center. Average route execution times for the Bethel-Tate School District and the New Richmond School District are 35-40 minutes and 55 minutes respectively. The assumed mobilization time in the evacuation time estimate is one hour. It is noted _

) that in this situation the students are alrsady assembled, boarded upon the bus, and ready for quick dispatch to the proper center upon the bus' arrival at the school.

The first sentence of contention 21 d 1 is false. It is the coumon practice in both Campbell and Clermont Counties dur-ing snow emergencies, floods, or other natural disasters to con-tact buses enroute by calling a home or other location on the portion of the route yet to be driven and instructing the resi-dent to notify the bus driver upon its arrival at that point.

The school buses of West Clermont School District, Clermont Northeastern School District, and Kenton County School District have been identified in the emergency plans as being a readily e

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available resource in aiding New Richmond, Bethel-Tate, and Campbell County School Districts respectively, should the need ;

for additional vehicles arise. Obviously, the availability of

these buses is considered before initiating an evacuation that i i

! would require the use of these additional buses. Should the i t i i time of day be such that the buses were in use servicing their l own districts, this limitation on bus supply is considered. !

Communication with school buses in contiguous districts is ;

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the same as communication with school buses of the three school !

districts in question: await the arrival of the bus at the school terminus, or notify a residence along the route. l I

The response to contention 21 d 3 is the same as that j discussed previously except that the students would be arriving i

)~

at their homes (within a period of time less than the assumed l

( mobilization time) and begin evacuation with their families, rather than arriving at the school, where they would be t

I evacuated collectively.

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APPLICANTS' TESTIMONY REGARDING i CONTENTIONS 21 e 1, 21 e 2, and 21 e 3 J

l Contention 21 e 1]. The buses utilized for student transportation of pupils in the New Richmond and Bethel-Tate School Districts of Ohio and the Campbell County School District of Kentucky are maintained by their drivers at the driver's residence or other parking area, in which the buses are parked during the school day offsite of the af fected schools within the respective dis-tricts. Upon notification that it is necessary to conduct an evacuation of school children there are no means to assure the contact of all drivers to summon the buses to the school sites, except as such drivers could be reached by telephone at their homes or other normal place during the non-driving period of the school day. Where the driver could not be contacted and in-structed to drive the bus to the school site, that bus would be removed from the transportation means of evacuation. School bus drivers during non-driving school hours are involved ir, other modes of employment, including farming, and in leisure pursuits, .

during which time they may not be accessible by telephone con-tact. The use of pagers to summon drivers are inadequate for transmission and notification over a distance of 12 miles.

Shopping areas and other areas for indulging in leisure pur-suits, and areas in which one might be conducting business are beyond the 12-mile range for paging. There is no provision in any plan that provides for notification to drivers. and as such there is no plan provision presenting reasonable assurance that buses can be summoned to the school site during an emergency.

21 e 21 The location of school buses during the school day ranges from 5 to 15 miles frora the school site and upon notification to the driver an approximate hour is consumed from the point of advising that evacuation is being ordered to the i point that the notified driver arrives at the school site to ;

commence transportation of evacuating children. r 21 e 3 ] . None of the three school districts have the i f acility or the relationship with their respective drivers to park and maintain school buses at each respective school site.

This circumstance removes any reasonable assurance that students can be timely and safely evacuated from school sites during a ;

radiological emergency. (No plan provision.)

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L Testimony The Campbell and Clermont County Plans provide reasonable assurance that school buses can be summoned to school sites i

within the plume exposure EPZ during an emergency and that i schools can be evacuated in a safe and timely manner. ;

i Several alternative means exist for notification of bus ,

i drivers, in addition to a telephone call from the School l District Transportation Supervisor. Those bus drivers within ;

the plume exposure EPZ, as part of the general public, will hear i i

of an emergency by means of the Prompt Notification System, ;

1 .

consisting of sirens and NOAA radios. During school hours they l t

could then proceed directly to schools for further instructions. ;

The use of pagers is not contemplated.

In New Richmond, school bus drivers have no other mode of f t

~

employment. Twenty-nine of Campbell County's 54 regular bus I drivers have no other employment and two-thirds of Bethel-Tate 's l drivers have no other employment.

Those drivers living outside the plume EPZ who are not at ,

i home during the emergency may receive notification over one of i:

the EBS radio or TV stations. Procedures have been developed ;

whereby the Superintendent of the Clermont County Board of Education will call the Greater Cincinnati Broadcasters Association to make an announcement regarding the schools, thereby increasing the possibility that school bus drivers who j are temporarily beyond reach of a telephone will be alerted to the emergency. As a final measure, the drivers may be summoned by dispatch of other personnel to their residences.

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!!alf of Bethel-Tate's, all of Felicity-Franklin's and 37 (of 58) of Campbell County's buses are parked at the school garages. All of New Richmond's buses are parked at the drivers' homes. A portion of the time required to evacuate school children is taken up with getting children assembled and prepared to board buses. While buses that are parked of f-site are travelling to the schools, preparations are being made at the schools so that children will be ready to board when the buses arrive. Thus, the fact that all buses are not already on site when an evacuation order is received does not necessarily create delays in getting an evacuation underway. As stated in Contention 21 e 2, "an approximate hour is consumed from the 1

point of advising that evacuation is being ordered to the point _

that the notified driver arrives at the school." An hour is the amount of time assumed in the evacuation time estimates for mobilization of the general public. Therefore, there is no delay or increase in the total evacuation time caused by drivers who keep buses at locations other than school sites.

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APPLICANTS' TESTIMONY REGARDING CONTENTIONS l 23(1), 23(3), 4(12), 23(4), and 23(5) !

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t Contentions {

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23 1]. The affected population of the involved counties j

ranges in education from elementary education to University !

trained and within the five-mile radius of the Zimmer Station is j

rural, farming,and factory employed populace. Flooding circum- ;

i stances and being within the tornado belt the population has i been instructed by various means as to protective actions to be l taken in the event of flood and in the event of tornado, as well j as the use of sirens and other types of warning device including

, door-to-door notification. In each situation there has been a l large segment of the population who telephone local police i k agencies to inquire if the siren is actual or for drill, not-withstanding the educational measures taken; and who upon being advised by door-to-door notification nonetheless neglect to take .

protective action until forced to so do by policy authority. l

Inquiry to police agencies have overloaded the trunk lines j l within the community serviced by an assigned number of telephone j t

trunk line. [No Plan provision. ] ;

! 23 3]. The " Circle of Safety" as the mode of educating the l af fected population as to the nature of nuclear power, radia- -

t tion, protective action, preparation is beyond the capabilities [

of the majority of the population within the affected crea. l Based on the average number of sentences per 100 words and the !

average number of syllables per 100 words the publication, in l accord with Fry's Readability Graph, is within college level [

j readability. The publication is too involved, too long and too !

j sophisticated in its writing style to be either read or under- l stood by a large segment of the involved population. The publi- i cation's style is comparable to text-book industry publications l which do not interest the average reader and due to length j f rustrate the average reader and deters complete reading. ;

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! Further, the publication in preliminary sentences attempting to j minimize the potential hazards directs the average reader to l stop reading those portions because the reader is initially ,

informed that the matter will probably not occur and this is extraneous information. The publication has no reasonable asurance of being read, understood or educating the population within the EPZ and thus has no educational value of informing i j the .af fected public of the matters necessary to be known by that !

i public to properly respond to an emergency at the Zimmer

! Station. [Clermont Plan, SII-F, Public Information, Attachment l F-1, pp. II-F-3, et seq. ; each of the Kentucky counties have the i same publication present in their plans] . j i

4 12]. The document known as the " Circle of Safety" is !

i written in vague language and language not calculated to insure l that the populace will take the appropr'iate protective measures !

in the event of a general emergency. l e

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23 4]. The plans provide no reasonable assurance of the information to be disseminated to the public, permanent and transient, (to be mailed to all permanent population, placement i in local telephone books, or the installation of signs) will be sufficient to inform or in its method of dissemination (style),

will not minimize the hazards and deter the educational value of the material, or being written in such a manner that it is not readily understood by the public, e.g., " Circle of' Safety."

l [Clermont Pl an , II-F, Public Information pp. F-1 and 2; Campbell J

Plan , Basic Plan , p . V-2 ; Annex J , Public Information, pp. J-5 and 6; same information contained in Pendleton and Bracken

Plans].

23 5]. There is no plan provision, or adequate assurance presented, as to the method, manner and text of the publications to be posted for the information of the transient population,

particularly those visiting parks, historical sites and engaged j in recreation pursuits on and near the Ohio River, all of which are within the affected area. [No plan provision].

]

i Testimony As part of the Zimmer emergency planning ef fort, informa-

tion will be made available to the public on a periodic basis on -

how they will be notified and what their initial actions should be in an emergency situation. This program will be in accord-ance with the requirements of Section IIG "Public Education and Information" of NUREG 0654 (Rev. 1). Primary means for dissemi-nation of such information to members of the public living within the plume EPZ is by means of a document entitled " Circle of Safety," the latest draf t of which is attached to the tes t i-many of Dr. George Klare. The latest version is generally

similar in content to the version which was appended to the state and local emergency plans for the Um. !!. Zimmer Nuclear Power Station sent to the Board and parties. As was done with previous draf ts, copies of the latest draf t of " Circle of I

Safety" were sent to the involved governmental agencies having i

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jurisdiction within the plume EPZ. As detailed in Dr . Klare's I i

testimony, the purpose of the latect draf t was to simplify the f l

)

contents of the document and improve its readibility. ,

i

) It is ' contemplated that the document entitled " Circle of l l

Safety" (or a pamphlet or mailing similar to it) will be de- !

t livered at least annually to all residences and businesses within the plume EPZ. Along with " Circle of Safety" it is !

I i planned to send a copy of the pamphlet " Radiation: Measure for j 4

Measure" (a copy of which is attached) to the same recipients. f 1

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Reference to the latest draf t of " Circle of Safety" indi- l l cates that it covers the topics required by tiUREG 0654, namely- !

educational information on radiation; points of contact for i

additional information; 'a description of protective measures and . !

consideration of special needs of the handicapped.

{

In addition to the document " Circle of Safety," the Appli- f l

cants plan to include in the five telephone books, which are

. l distributed within the plume EPZ, specific information in a continual and simplified form as to what to do in an emergency I situation at Zimmer. A typical layout of these telephone pages I is attached to Dr. Klare 's testimony. Emergency instructions !

i will also be posted in public areas.

(

The readability of information provided to residents has j f

been improved, and short specific instructions are also given as

L a backup in the phone books. While nothing will prevent some -

residents from calling local authorities even though this is !

contrary to the specific instructions given in " Circle of j Safety" and the telephone book instructions, this should not ;

i lu'd

unduly delay evacuation. If lines to police are busy, residents are likely to turn to the radio or TV to gain further informa-tion. The Emergency Broadcast System stations would broadcast instructions suf ficient for those who had not read " Circle of Safety" or did not consult the telephone book. In any event, those individuals failing to take any action would be located during the evacuation verification runs done by emergency workers. These individuals would be given instructions person-ally. However, if any residents decide not to leave the area, this is a decision that they must, themselves, make. Merely because they refuse to leave does not represent any deficiency in the planning ef fort or the reasonableness of its implementation.

103

TESTIMONY OF DR. GEORGE R. KLARE RELATING TO CONTENTIONS 23(3), 23(4) 4( 12) and 23(5) l My name is Dr. George R. Klare. My address is Department of Psychology, Ohio University, Athens, Ohio 45701. My title is Distinguished Professor of Psychology. I have been af filiated f with Ohio University since 1954 in various professional posi-tions. I obtained a PhD Degree in Psychology from the Univer-sity of Minnesota. My research and outside activity have dealt with reading, readability, and psychological measurements. I have written a number of articles and books on readability and

! the measurement of readability for various applications. A more complete statement of my professional qualifications is appended l hereto and incorporated herein by reference. -

t .

I was requested by The Cincinnt.ti Gas & Electric Company to review a document entitled " Circle of Safety." As I understand it, this was in draf t form in the state and local plans for the Um. H. Zimmer Nuclear Power Station. The Company requested tha t I review the readability of the document and recommend changes to improve the readability of the text without affecting the basic content.

3 Readability is defined as that quality of the style of 1

writing which makes it easy or hard to read and understand.

I analyzed the readability of the document as requested and made those changes which I considered necessary. The basic technique I used in analysis was the Fry Readability Graph. The Fry method uses counts of word lengths in syllables and sentence lengths in words to arrive at an index of difficulty. I then 104

simplified the vocabulary and the sentence structure of the document to reduce the level of dif ficulty and thus improve the readability.

After editing the document and discussing it with Company experts to assure that the substantive content was unchanged, I again checked the text against the Fry Readability Graph. The

" Circle of Safety" which is attached to my testimony now has a rating of 7th grade readability level. I da not believe that it would be appropriate or necessary to attempt to reduce its level further as determined by the Fry Readability Graph. At some point, the message content of the material would be affected.

There are certain key words, for example, for which there is no adequate substitute. One such term is " emergency." While this %

word has four syllables and thus raises the average syllable count, it will not af fect comprehension. Studies have shown that the word " emergency" is understood to mean "need for quick action" by 75% of 4th graders. I have selectively checked the comprehensibility of certain other words using such generally accepted methods. Based upon my experience in using accepted readability techniques, I have assured that the text of " Circle of Safety" should be readable by a large segment of the population.

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J The Company also asked me to review and revise two pages of .

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j text which I understand are to be included on the inside back i t

l cover of telephone books used in the vicinity of the Zimmer ,

i 1 Station. I understand it to contain the essential instructions I j I should an emergency occur. I applied the same technique to the !

l review and rewriting of this text. The Fry Readability Graph i 1 >

( places this revised material at the 5th grade readability level. ;

j Dased upon my analysis, I have concluded that this two-page text f (a copy of which is attached hereto) will now be readable by even a still larger segment of the population than " Circle of I Safety."

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PERSOEAL AWD PROFESSIONAL INTonMATIOW (As of September,1981)

George R. Klare l

Office Address: Home Address:

Department of Psychology 5 Pleasantview Drive 110-CPorterFal$ Athens, Ohio 45701 Ohio University Athens, Ohio 45701 1 Phone: (614)-594-6032; (614)-594-5964 or 594-5965 Phone: (614)-593-3675 Birthdate: April 17, 1922 Married: three children Birthplace: Minneapolis,1:innesota Education: University of Nebraska (Regents Scholarship), 1940-41; major -

Engineering.

University of Minnesota, 1941-42; majors - Engineering & Psychology. :

University of Missouri (U.S. Army Air Force),1943.

University of Minnesota, 1946-50; major - Psychology, minors - ;

English & Educational Psychology; B.A. cum laude, 1946; M.A., t 1947; Ph.D., 1950. ;

Professional Experience:

(1) September, 1954 - present. Ohio University: Assistant Professor to ,

Professor, 1962-1979, Distinguished Professor,1979 , Department of l Psychology; Chairman, 1959-63; Acting Dean, 1965 Dean, 1966-71 College of Arts and Sciences; Instructional Media Coordinator (Center for Instructional Development), 1972-75; Research Associate and Language Program Director, Computer-Aided Instruction Laboratory, Harvard University, 1968-69; Visiting Professor, State University of New York at Stony Brook, 1971-72; Visiting Professor, The University 1 of Iowa, 1979-1980. ?

Administration: Dean of College, working with 17 department chairmen in areas of humanities, natural sciences, and social sciences, and with approximately 350 faculty members and 3000 students, with assistance of one associate dean and two assistants to the dean.

Teachine: Undergraduate and graduate courses: general, statistics, industrial, experimental, testing (selection), personnel and vocational counseling, psychology c' communication, and programmed and computer-assisted instruction; graduate seminars in prose instruction and learning, readability, and document research methods. ,

Research: Research grant, 1981, Experimental Educational Services Fund, Ohio University (with G. Schumacher and F. Cronin); tescarch contract. '

Human Resources Research Organization, 1979; research contract, U.S.

Air Force (as sub-contractor to Westinghouse Electric Corporation), i 1977-78; research contract, Bell System Center for Technical Education, 1977; Fulbright travel grant, U.S. - U.K. Educational Commission, for joint research with Michael Macdonald-Ross of the Open University, ;

England, 1977-1981; research contract, Bell System Center for Technical l Education, 1976; research contract, United States Armed Forces Institute.

l 1972-1973; research contract, United States Armed Forces Institute,1971; j l

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Georg2 R. Klare 2 Project Director United States Office of Education (Adult Basic Education' '

grant, 1968-70; Co-holder, Guill and Scroll Research grant, 1965-66; Baker Award, 1964-65 (European travel and writing); work on National i Defense Eduer. tion Act grant, Summers of 1962 and 1963; National Project ,

in Agricultural Communications grant. 1958-1960. i Outside Activities: Consultant. National Center for Materials and Curriculum Devri)pment. University of Iowa,1981; Editorial Advisory '

t Board. The Ren 7.pg Teacher,1981-; Fellow American Psychological Association, l? O; Consultant. American Telephone and Telegraph.1979- ,

1981; editorial advisory board. Information Design Journal,1979-; !

consultant. Bell System Center for Technical Education, 1978-1980; con- l sultant, Center for Educational Experimentation Development, and I Evaluation University of Iowa, 1978-79; consultant. Human Resources !

Research Organization. Alexandria, Virginia, 1978-79; consultant, Time. '

Inc. (Time-Life Booka), 1977-1979; consultant, U.S. Army, Fort Benjamin :

Harrison, 1979; invited seminar. Bell Laboratories, Murray Hill, New i Jersey, March 3, 1973; invited participant. NATO Conference on Visual i Presentation of Information. Het Vennenbos, Netherlands, Sept. 4-8, i 1978; invited speaker Institute for Perception Research. Eindhoven. ;

Netherlands, Sept. 1,1978; Best of Show award, journal article com- i petition, 25th International Technical Communication Conference Dallas, l Texas, May 11. 1978; member, Advisory Board. International Reading l Association Dictionary of Reading Terms, 1977-80; member, Ohio Merit l Scholarship Advisory Committee, 1977-1979; consultant, Bell Laboratories, i Murray Hill, New Jersey. 1976; Expert Consultant. Conference on Reading !

and Readability Research in the Armed Services. U.S. Navy Post-Graduate l' 3

School, Monterey, Calif., Oct. 27-30, 1975; Advisory Editor, Instructional Science,1975-; invited address, "A Second Look at the Validity of i Readability Formulas," annual meetings, National Readine Conference. I Dec. 4-5, 1975 St. Petersburg, Florida; consultant, U.S. Navy Personnel !

l Research and Development Center, San Diego, 1975; consultant " Write to i Read" Research Project School of Allied Health Professions State l

University of New York at Stony Brook, 1975;., consultant. Bell System j Center for Technical Education, Lisle, Illinois, 1975-1978; Invited I Lecturer. Institute of Educational Technology. The Open University, (

England, March, 1975; consultant, Electronic Systems Support Division.

l Westinghouse Corporation, 1975; Invited paper on standards for textbooks, i Fifth International Reading Association World Congress on Reading. l Vienna, Austria, August 13, 1974; member, Chancellor's Advisory Committee l on Instructional Development (Board of Regents, State of Ohio),1973 .

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1978; member, Symposium on Educational Technology, State University of i New York at Stony Brook, sponsored by U.S. Office of Education and l National Center for Educational Technology, September 23-26, 1973; ;

licensed Psychologist. State of Ohio Board of Examiners,- 1973-; Editorial !

Board, Journal of Reading Behavior, 1973-78; consultant, Western Electric l' Service Division Training Organization,1973; Associate Editor, Journal of Communication 1971-74; consultant D.C. Heath and Company, 1971; instructional staff, U.S.O.E.-sponsored research training session on the Psychology of Written Instruction, Columbia University. 1971; liaison l between the International Communication Association and President Nixon's .

National Reading Council, 1970-72; consultant, IDA. 1970-72; consultant.* j Harvard Computer-Aided Instruction Laboratory, 1969-70; colloquium ,

lecturer, Bell Telephone Labs July 23, 1969; consultant Boston Public j Schools 1968; !

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t George R. Klara 3 Editorial Consultant, Reading Research Ouarterly, 1968-69; speaker, Fational Symposium on Communicating Policy and Procedure, Main i

International Conference Room State Department. Washington, D.C.,

Nov. 27-29, 1967; featured speaker, annual conference, Canadian Farm Writers Federation. Toronto, Canada, Nov. 12-13, 1967; Lecturer. NDEA Institute for Advanced Study in Educational Media (Featuring Programmed Instruction) University of Pennsylvania, July, 1966, sponsored by the U.S. Office of Education in cooperation with the University of Pennsylvania; member and speaker, Symposium ;

on Verbal Learning Research and the Technology of Written Instruction, ;

Columbia University, March,1966, sponsored by the Office of Naval Research; Research Fellow, Summer, 1964, and consultant, 1962 to 1965, ;

Resources Development Corporation; staff member and workshop leader, Madison-Florham Park Uriters Conference, Sununer,1964; consultant and lecturer in communication, First International Christian Writers .

Seminar, Green Lake, Wisconsin, August, 1962; Senior Research Engin- r eer. Advanced Systems. Research and Development Division of Autonetica, a division of North American Aviation, Summer, 1961; Associate Editor (Communication Theory). The Journal of Communication, 1961-66; Exec- -

utive Assistant (consnunication consultant), Computers and Data !

Systems Division of Autonetics, a division of North American Aviation. .

Summer.1959; consultant and lecturer, c-=4 cation training sessions, !

National Project in Agricultural Communication 1957-59; consultant i and lecturer in communication, Committee on World Literacy and j Christian Literature, sessions of 1953 and 1960; staff member and i vorkshop leader, New York City Writers Conference, sessions of 1956 and 1957.

Honors: Listing in Who N Who in the World, Pho's Uho in America, and American !

Men and Women of Science. ,

(2) January, 1952 - August, 1954: nesearch Associate Department of Psychology, University of Illinois (Air Force Training Research l Proj ect) . ?

I Research: Direction of three to five persons in studies of the l

communication and learning of technical training material.

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Outside Activities: Consulting with 3300 Training Publication !

Squadron, USAF, 1953-54. l (3) July, 1950 - December,1951; Staff Psychologist. Test Division The l Psychological Corporation, New York, New York. !

1 Duties: Test construction and research; test manual writing, editing i and publication.

t Outside Activities: Lecture 6 Institute for Industrial Editors.

University of Wisconsin, 1951.

(4) September,1946 - June,1950: Graduate Assistant (teaching, administration, counseling) to Instructor University of Minnesota.

I I

.Georsq R. Klaro 4 Duties: Laboratory assistant, and assistant to psychology faculty members; ed=inistrative assistant to Dean of College of Science, Literature and the Arts; educational and vocational counselor.

Teaching, Research and Writing Interests: Primary interest in teaching, research and writing in the psychology of language and communication and in computer-assisted instruction and programmed instruction; other major interests in personnel and vocational selection and counseling, psychological measurement, and industrial psychology (including human engineering applications); continuing interest in teaching and writing in general and educational psychology.

Military Experience: Private to ffret lieutenant, U.S. Ar=y Air Corps, February,1943, to December,1945. Served as navigator on heavy bonbers with IC0th Bomb Group in England; shot down over Germany in December, 1944, and was prisoner-of-war until May, 1945; received Purple Heart, Air Medal, Presidential Unit Citation, and area ribbons; honorably discharged. !

Publications: See following pages.

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Georgo R. K1cro 5 PUBLICATIONS

. 1950 "Understandability and Indefinite Answers to Public Opinion Questions," Inter-national Journsi of Opinion and Attitude Research, 1950, 43,, 91-96.

1952 "A Table fo'r Rapid Determination of Dale-Chall Readability Scores," Educational Recearch Bulletin, 1952, 31, 43-47.

"A Note on ' Simplification of Flesch Reading Ease Formula'," Journal of Applied Pcychology, 1952, 36, 53.

"M:asures of the Readability of Written Communication: An Evaluation," The Journal of Educational Psychology, 1952, 4],, 385-399.

1953 "The Reading Interests of Airmen During Basic Iraining," (with L.M. Gustafson and J.E. Mabry), San Antonio, Texas: Human Resources Research Center, Lackland Air Force Base, November,1953, (Research Bulletin 53-54).

1954 .

Enow Your Reader, (with Byron Buck), New York: Hermitage House, 1954. Chapter 11 reprinted in Efficient Reading, edited by James I. Brown.

Review of Charles M. Redfield's Communication in Management, Journal of Applied l Psychology, 1954, 38,8 138-139.

"The Relationship of Verbal Communication Variables to Icmediate and Delayed Retention and the Acceptability of Technical Training Haferials," (with J.E.

Mabry and L.M. Gustafson), San Antonio, Texas: Air Force Personnel and Training Research Center, Lackland Air Force Base, December,1954 (Research Bulletin 54-103).

1955 "The Relationship of Style Difficulty to immediate Retention and to Acceptability

, of Technical Material," (with J.E. Mabry and L.M. Gustafson), The Journal of l Educational Psychology, 1955, 46, 287-295.

"The Relationship of Patterning (Underlining) to Immediate Retention and to Acceptability of Technical Material," (with J.E. Mabry and L.M. Gustafson),

l Journal of Applied Psychology, 1955, 39, 40-42. !

i l "The Relationship of Human Interest to immediate Retention and to Acceptability of Technical Material," (with J.E. Mabry and L.M. Gustafson), Journal of Applied Psychology, 1955, 39,, 92-95.

Georgo R. K1cra 6 PUBLICATIONS - continued "The Relationship of Immediate Rotention of Technical Training Material to Career. Preferences and Aptitudes," (with L.M. Custafson and J.E. Mabry), The Journal of Educational Psycho h , 1955, 46_, 321-329.

R; view of Eleenor M. Peterson's Aspects of Readability in the Social Studies, Journal of Appited Psychology, 1955, 39, 141-142.

i , 1957_

f "The Relationship of Typographic Arrangement to the Learning of Technical Trcining Material," (with W.H. Nichola and E.H. Shuford), Journal of Applied

] Psychology, 1957, 41,, 41-45.

1

] " Student Reactions to Topics in General Psychology," (with A.H. Fuchs and M.S.

, Pullen),The American Psychologist, 1957, 12, 219-221.

I "The Relationship of Style Difficulty, Practice, and Ability to Efficiency of Reading and to Retention," (with E.H. Shuford and W.H. Nichols), Journal of Applied Psychology, 1957, 41,, 222-226.

1958 i

j "The Relationship of Format Organization to Learning," (with E.H. Shuford and i W.H. Nichola), Educational Research Bulletin, 1958, 37, 39-45.

)

1959

, Review of Jeanne 9 Chall's Readability: An Appraisal of Research and Appli-ca ti on , Educational Research Bulletin,1959, 33,, 49-50.

" Comment on ' Cinematography as a Method in Research'," Journal of Counseling Psychology, 1959, 6, 243-244.

1961 4

"G neral Models of Catmunication Research--A Survey of the Developments of a

! Deccde ," (with F. Craig Jchnson), Journal of Communicar. ion, 1961, 11, 13-26.

I 1962 "Fsedback: Principles and Analogies," (with F. Craig Johnson), Journal of C mmunication, 1962, 12, 150-159.

1963 2

I "A Selectiva Split Level 31 biography on Programmed Learning " East Lansing, Michigan: Program Press,1963.

1 i

e

-s

PUBLICATIONS - continu:d The Measurement of Readability, Ames: Iowa State University Press, 1963.

Now available in facsimile (paperback) edition.

1964

What Readability can Do For You," (with Robert S. Laubach), Syracuse, New York: New Readers Press, 1964.

Review of " Gyro Fundmentals," (a learning program by Stanley L. Levin), Train-ing, 1964, 1,, 10.

1966

" Comments on Bormuth's ' Readability: A New Approach'," Reading Research Quarterly, 1966, 1., 119-125.-

1967_

Elementary Statistics: Data Analysis for the Behavioral Sciences, (with Paul A. Games), New York: McGraw-Hill Book Co. ,1967.

}!sasuring the Peadability of liigh School Newspapers, Parts 1 and 2, (with L.R. Campbell), Iowa City, lowa: Quill and Scroll Foundation, 1967.

Instructors' Manual to Accompany Elementary Statistics: Data Analysis for the Behavioral Sciences, (with Paul A. Games), New York: McGraw-Hill Book l Co., 1967.

"The Interpolation of Instructional Objectives During ' Breaks' in Recorded Speech Lectures," (with Paul A. Games and F. Craig Johnson), Speech Monographs, 1967, 34, 437-442. (

1968 y "The Role of Word Frequency in Readability," Elementary English, 1968, 45,,

12-22. Reprinted in J.R. Bormuth (Ed.), Readability in 1968 (A Fesearch Bulletin Prepared by a Committee of the National Conference on Research in English, 1968).

1969

" Automation of the Flesch ' Reading Ease' Readability Formula, with Various Options," (with P.P. Rowe, M.G. St. John, and L.H. Stolurow), Reading Research Quarterly, 1969, 4, 550-559. -

1970

" Writing w1th a Helping Hand." In H.B. Pepinsky (Ed.), People and Information.

N;w York: Pergamon Press, 1970.

eenso -

8 1

PUBLICATIOWS - continucd 1971 "Some Empirical Predictors of Readability." In E.Z. Rethkopf and P.E. Johnson (Eds.), verbal Learning Research and the Technology of Written Instruction.

N;w York:

Teachern College Press, Columbia University, 1971.

"Research Critiques," Elementary English, 1971, 48,, 675-681.

1972 "Tho Cloze Procedure in Adult Basic Education," (note with Mark A. Sherman),

Jcurnal of Reading,1972, J5, 624.

"Further Experiments in Language Translation: Readability of Computer Trans-lctions,"

1-29. (with H.W. Sinaiko), ITL (Review of Applied Linguistics), 1972, 15, "Tha Cloze Procedure: A Convenient Readability Test for Training Materials and Translations," (with H.W. Sinaiko and L.M. Stolurow), International Review of_ Applied Psychology, 1972, 21,77-106.

1973 "Further Experiments in Language Translation:

A Second Evaluation of the Read-chility of Computer Translations," (with H.W. Sinaiko), ITL (Review of AppIted Linguistics), 1973, 19, 29-52. -

" Analysis of the Readability Level of Selected United States Armed Forces institute Printed Instructional haterials," (with Kim Smart), The Journal of Educational Resecrch, 1973, 67, 176.

" Factors Relating to Correspondecce and Other Non-Traditional Instruction: The Role of Readability." In Educational Resources Information Center Clearing-housa in Reading and Communication Skills, with abstract l'n Research in Educa-tion, November, 1973.

1974 "Assassing Readability," Reading Research Quarterly, 1974-75, 10,62-102. To ha abridged in John Chapman and Pam Czerniewska (Editors), Reading: From Frocess to Practice (Routledge and Kegan Paul, Ltd., Henley-on-Thames, England).

" Readability and the Behaviors of Readers."

(Eds.), Educational Technologies: Productivity In S.A. Harrison and L.M. Stolurow ten, D.C.:

in Higher Education. Washing-U.S. Dept. of Health, Education and Welfare, January,1974 "A Reaction to Chicago's TV College: A Televised Open Learning Model." In S.A.

Rtrrison and L.M. Stolurow (Eds.), Educational Technologies: Productivitv in i Highar Education, Washington, D.C.: U.S. Dept. of Health, Education and l W21f are, January , 1974.

l

f PUBLICATIONS - continu:d 1975 A Manual for Readable Writing. 119A Roesler Road, Glen Burnie, Maryland: REM Company, 1975.

Portions (16 pages) of The Measurement of Readability translated into French and reprinted in Comment Mesurer la Lisibilite (Brussels, Belgium: Editions Labor, and Paris, France: Fernand Nathan, 1975).

1976

" Judging Readability," Instructional Science, January, 1976, 5, 55-61.

" Selecting Textbooks: Some Preliminary Thoughts," (with Michael Macdonald-Ross).

In J. E. Merritt (Ed.), New Horizons in_ Reading. Proceedings of the Fifth World Congresa in Reading, Vienna, Austria, August, 12-14, 1974. Newark, Delaware:

International Reading Association, 1976, 318-330.

" Readability of Behavior Modification Texts: Cross-Comparison and Comments,"

(with Frank Andrasik and William Murphy), Behavior Therapy, 1976, 7, 539-543. ,

"A Second Look at the Validity of Readability Formulas," Journal of Reading Behavior, 1976, 8,, 129-152.

" Comments," on papers by Curran, Muller, and elsewhere, in T.G. Sticht and D.W. Zapf (Eds.), Reading and Readability Research in the Armed _ Services.

Alexandria, Virginia: Human Resources Research Organization, 1976, 202, 265, 282-289.

1977 '

" Readable Technical Writing: Some Observations," Technical Co=munication, 1977, 24, 1-5. Received outstanding articic award (Best of Show), 25th International Technical Communication Conference, Dallas, Texas, May,1978.

" Readability," signed article in 5.B. Wolman (Ed.), Internat_f onal Encyclopedia of Psvchiatry, Psychology, Psychoanalysis, and Neurology. Boston, Massachusetts:

Aesculapius Pubishers, 1977.

Introduction to " Testing and Grading" articles. In S. Scholl and S. Inglis (Eds.),

Teachin2 in Higher Education. Columbus, Ohio: Ohio Board of Regents, 1977.

197.8 t "Re-opening the Cloze Blank Issue," (with Robert Rush), Journal of Reading, Behavior, 10, 203-210.

" Factor Analyses of Three Correlation Matrices of Readability Variables," (with Eileen Entin), Journal of Reading Behavior, 1978, 10, 279-290.

l

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4 Gr.org3 R. Klara 10

" Assessing Peadability," Chapter 1 (Section 4) in L. J. Chapman and P. Czerniewska (Eds.), Readine from Process to Practice. London: Routledge and Kegan Paul, in association with Open University Press,1978, pp. 248-274.

" Textbooks," (with James Hartley). In D. J. Unwin and R. MacAleese (Eds.),

Encyclopedia of Educational Media, Communication and Technoloav. London:

The Macmillan Press, Ltd., 1978, pp. 770-716.

"Some Interrelationships of Readability, Close, and Multiple Choice Scores on a Reading Comprehension Test," (with Eileen B. Entin), Journal of Reading Behavior, 1978, 10,, 417-436.

1979 Review of The Visual Impact of Scholarly Articles, by May Katzen. The Library Guarterly, 1979, 4_9,, 229-231.

" Readability Standards for Army-Wide Publications." Fort Benjamin Harrison, Indiana: Directorate of Evaluation U.S. Army Administration Center,1979 (Evaluation Report 79-1).

"Fendability of Materials and Student Comprehension." In Peadine and Beyond, Report of the Helen F. Robinson Third Annual Reading Conference. Athens Ohio:

College of Education, Ohio University, 1979.

" Differential Relationships of Two Versions of Cloze Tests to Vocabulary and Reading Comprehension " (with Eileen B. Entin) . In M. L. Kamil and A. J. Moe (Eds.), Reading Research: Studies and Aonlications. Twenty-eighth Yearbook of the National Reading Conference. Clemson, South Carolina: The National Pead-ing Conference, Inc., 1979, pp. 68-71.

"Uriting to Inform: Making It Readable." Information Desien Journal, 1979, 1,98-105. ?

1930

" Components of Answers to Multiple-Choice Questions on a Published Reading Comprehension Test: An Application of the Hanna-Oaster Approach," (with Eileen B. Entin) . Readine Research Ouarterly, 1980, 15,, 228-236.

" Operational Consequences of Literacy Gap," (with J. D. Kniffin, C. R. Stevenson, E. B. Entin, S. L. Slaughter, and L. Hooke) . Brooks AFB, Texas: Air Force Systems Command, May,1980 (AFHRL-TR-79-22) .

A Manual for Readable Writing. Fourth Revised Edition. 514 Crain Highway, Glen Burnie, Maryland, 21061: PEM Company, 1980.

"A Possible Framework for the Study of Readability." Keynote address in T. E. Curran (Ed.), Tri-Service Literacy and Readability: Workshoo Proceedings.

NPRDC Special Report 80-12. San Diego, California: Navy Personnel Fesearch and Development Center, March,1980, pp. 3-16.

i .

Georga R. K1cra 11

" Recapitulation." In T. F. Curran (Ed.), Tri-Service Literacy and Pendability:

Workshop Proceedings. PPPDC Special Report 80-12. San Diego, California:

Navy Personnel Research and Development Center, March,1980, pp. 86-89.

1981 Practical Aspects of Readability. Milton Keynes, England: Institute of Educationa:

Technology, The Open University,1981.

" Readability and Comprehension." In R. S. Easterby and H. Zwaga (Eds.), Visual Presentation of Information. London: Wiley, in press.

( Readability and Behavior Modification Training Texts: Updated Findines," (with F. Andrasik. S. R. Edlund, and R. A. Butz). Behavioral Counseling Ouarterly, in press.

" Readability " signed entry in H. E. Mitzel (Ed.), Encyclopedia of Educational Research. New York: The Free Press, in press.

" Readability Indices: Do They Inform or Misinform? Information Design Journal, in press.

4

DMAFT CIRCLE OF SAFETY January 15, 1981

l h'3

! d)1-.d ]7I I. INTRODUCTION It is unlikely that therr will ever be an emergency at the Um . H . Zimmer Nuclear Power Station which would af fect you.

State and local governments must, however, prepare a complete plan for you and others who live in this area to follow. If there is a chance you may be affected, that plan will be used.

This handbook tells you about the plan and what you may be asked to do if there is an emergency. Here are some terms you need to know, since they will come up of ten as you read.

EMERGENCY -- means a Zimmer emergency and possible danger from radiation.

ZONE -- stands for Emergency Planning Zone, a circle about 10 miles in all directions f rom the Zimmer Plant. -

PLAN -- a short term for the steps you are to follow if you live in the Zone. This handbook describes the Plan and tells you what steps to take if there ever is a Radiation Emergency.

PLEASE READ THIS HANDBOOK AND KEEP IT IN A SAFE PLACE SO YOU CAN LOOK AT IT LATER IF YOU NEED TO.

If you have any questions, call one of the phone numbers inside the back cover of the handbook. Be sure that all members of your f amily read this handbook too, if they can; tell those who cannot read what is in it. If you have neighbors who might need help, talk things over with them. The best way to be sure you and others are safe if there is a Radiation Emergency is to j know what steps to take and to work together.

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IIbmf.

.a l The Zimmer plant is on the east bank of the Ohio River in Washington Township of Clermont County, Ohio. Moscow, Ohio, the nearest town, is south of the plant. Campbell, Pendleton, and Bracken Counties of Kentucky are across the river from the plant. Cincinnati Gas & Electric Company runs the plant.

II. RADIATION EMERGENCIES

A Radiation Emergency occurs when radioactive matter is l

l released, or if there is a chance that it may be. Most emergen-1

] cies are so small that you need not do anything. When the emer-gency is greater, you may be asked to stay inside or even move l to a safer place farther away from the Zimmer Plant. At such times, you should do what local and state officials tell you. A Radiation Emergency almost always develops slowly, so you will have plenty of time to listen to warnings on radio and TV. You will also have time to review the Plan in this handbook.

Radio and TV stations in your area are ready to broadcast special news about a Radiation Emergency if that is needed .

Both the broadcasts and this handbook will tell you what, if J anything, you should do. Nuclear power plants are built and run to hold down the chance of a really bad accident. They have special " engineered safeguards" to protect those who live and work around the plants if an accident occurs.

1 1

j d

l l State and local police, along with other emergency workers,

[

have always been in charge during disasters like floods and i storms. They will also be in charge during a Radiation i

! Ehergency. They will ask you to cooperate with them if a

! Radiation Emergency ever occurs. They will have expert advice J

j and can tell you the best steps to protect your health and safety. This handbook will help them and you.

}

J i

i III. RADIATION EMERGENCY PLANS I

! The Federal Energency Management Agency and the Nuclear i

i Regulatory Commission makes sure that the Radiation Emergency i

j Plan for Zimmer meets strict new federal rules. All nuclear 1

plants in the United States must be able to quickly reach all -

1

persons in the Zone and tell them of a serious emergency. The i

Plan for the Zimmer Plant has been made by the state and county

] agencies below.

Ohio Disaster Service Agency

. Kentucky Division of Disaster and Emergency Services I Clermont County Disaster Services Agency Disaster and Emergency Services agencies in j Campbell, Pendleton, and Bracken Counties These agencies have decided together what to do if a Radiation j

l Emergency occurs and who will be in charge.

I

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)

3 4

1 4

_-- . . - _ . _ . _ , _ _ _ ~ . -

UD $

dII'u A. The Zone (The Dmergency Planning Zone)

The Zone covers a circle about 10 miles in all directions from a nuclear power plant. The Zone for the Zimmer ' plant covers parts of Clermont County in Ohio and parts of Campbell, Pendleton, and Bracken Counties in Kentucky. The Evacuation Route Map in the middle of this handbook shows the Zone.

LOCATE WHERE YOU LIVE IN THE ZONE AND MARK IT ON THE MAP.

B. Exposure to Radioactive Matter Radiation occurs in nature in many forms. It comes f rom the sun and stars, from the soil, and even from our own bodies. Radiation comes from within the nucleus

( inside ) of the atom. Nuclear power plants use the heat produced when uranium atoms split to make electricity.

Radiation comes from this split too. However, nuclear plants block the release of this radiation in'a number of ways. The Plan described in this handbook can protect you if radiation is released by accident. You can get more details about radiation from the attached booklet called RADIATION: MEASURE FOR MEASURE.

C. Kinds of Emergencies The Four classes of Radiation Emergencies can occur at the Zimmer plant are:

4

O w4 LJ g (1) Unusual Event This is a minor problem. Experts at the plant expect the release of little or no radioactive matter.

They tell the Nuclear Regulatory Commission and state and local agencies right away, but that is all. You might later hear of an Unusual Event from a newspaper or on the radio or TV. Yo u do not have to do anything.

(2) Alert This is still a minor problem. A small release of radioactive matter is possible, so this is more serious than an Unusual Event. Experts at the plant tell federal, state and local agencies about the _

problem. Checks outside the plant may be made as needed. Experts expect the release of matter only in the plant. You do not have to do anything.

(3) Site Area Emergency This is more senere than an Alert. Some releases of radioactive mattet have occurred, or experts believe they will occur outside the plant. They'tell federal, state and local agencies so they can decide if you will r

need to know. These agencies then get ready to act.

They begin to make continuous checks and reviews of the problem outside the plant area. You may have to do something to protect yourself during a Site Area l

Emergency. Official Emergency Broadcast System !

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stations or your special weather radio will tell you what to do.

(4) General Emergency This is the most severe class. Releases of radioactive matter have occurred, or experts at the plant expect them. These releases could possibly

expose persons outside the plant area to radiation.

The experts at the plant tell federal, state, and local officials right away. Official Emergency Broadcast I

System stations or your special weather radio will tell you what to do and how to protect yourself.

i

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IV. WAYS TO NOTIFY AND PROTECT YOU If there is a Radiation Emergency the Zimmer plant will i

inform public officials. These officials might ask you to stay inside your home or to leave the Zone.

Please listen carefully when told how to protect yourself. Do not leave the Zone unless told to do so.

A. Ways to Notify You.

A Prompt Notification System will inform those who live

or travel in the Zone. This system uses

. Warning sirens

. Special weather radios in homes

. The Emergency Broadcast System

)

,m c3 This system will give quick notice to those in the Zone.

1 Checks by persons going to each house or other building will be made later.

Most persons in the Zone should be able to hear warning sirens. Special weather radios will be placed in homes where the sirens cannot be heard. As an added measure, these radios will also be placed in all homes five miles or less f rom the Zimmer Plant. Thus, many homes can be reached through both sirens and radios.

If you are warned of a Radiation Emergency by siren or special weather radio, tune your own AM or FM radio or TV set to an Daergency Broadcast System station. Most radio and TV stations are part of this system. You will be -

told what to do in this way. Avoid use of the phone. DO NOT phone local police or fire officials for information.

B. Ways to Protect Yo u You may be told to take shelter or to move to a safer place. Please pay close attention to the broadcasts and this handbook so you will know what to do.

When you know what to do and need no more help, please j i

show this by one of these two ways.

(1) Place the green card saying I HAVE BEEN i

NOTIFIED on your f ront door or window so it can be seen from the road. This is the card in the middle of this handbook.

m m l

_ l (2) Tie a large towel or cloth on your front door or mailbox so it can be seen f rom the road.

Emergency workers will drive along all roads in the Zone to check on these signs. They will stop at all homes which do not show a sign to see if help is needed.

1. If Told to Take Shelter Where You Are

. If you are told to take shelter, enter your house or other building where you are at the time and stay there.

. Close doors, windows, and other openings to help keep out radioactive matter in the air. -

. Turn off air conditioners or other systems which take in outside air.

. Added things you can do are listed below.

When you go indoors, first take off your shoes. Then wash your face and hands, especially before you handle food or any objects in your house. This will help you to hold down the chance of spreading radioactive matter in the house.

Cover up any food not already covered or put it in the refrigerator. If radioactive matter has come into your house, this will help to keep it out of your food.

c3 D,)

0,

_J JL .

If possible, eat and drink only from sealedcansorbothles. After being told to take shelter, do not eat fresh fruit or vegetables from the garden. Broadcasts on the Emergency Broadcasting System or special weather radio will tell you what to do about food and water while you are inside your house or business.

2. If Told to Move to a Safer Place (Evacuate)

An emergency may require that some or all of you who live in the Zone move to a safer place. How many I of you would have to move would depend on the weather and how severe the accident was. This move could last -.

f rom a few hours to a week or so. Remember to keep your house locked properly to protect items of value you have left in it. If you have no car for the move, see if a neighbor will give you a ride. If this is not possible, emergency workers will provide a way to move you out of the area.

Please do not move, however, unless told to do so.

Be prepared at all times. You might have to move because of several kinds of emergencies, such as nuclear, floods, tornadoes, and chemical spills. Here are four good ways to prepare yourself to move quickly.

_9_

~

id C{3 UI LJ 4 (1) Collect your important papers and store them in a safe place. Keep them all together so you will not vaste time looking for them.

(2) Make a list of things you will need to take with you. Keep it handy.

a. Items to Take During a Move Do not take more than you will need.

The items below should be considered.

1. Personal items

. soap and towels

. shaving articles

. toothpaste and toothbrushes

~

. toilet paper

. required papers and cards (car registration, driver's license, credit cards, (etc.)

. prescription medicines and prescriptions

2. Infants' and children's supplies

. disposable diapers and baby powder

. baby bottles

. milk or baby formula (dry or ;

i h

canned only) )

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-1A- ._ . _ _ _ ___ -, . - _ _ . i

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. favorite toys for going to l

sleep

3. Other supplies 4

. flashlight

{ . portable radio

. plastic or paper bags

. tools for car repairs.

Do not turn your pets loose and do not take them with you to the emergency Reception /

Relocation Center. You can shelter them in the house or take them out of the Zone to i

some other safe place. Police and other public of ficials will patrol the area to -

protect your property and the things you have left behind.

i b. Transportation J

1. Use your own car, or ride with a neighbor if you can.

2. Obey traffic signs and signals, and traffic officers.

i

3. Take your time when driving.

If you have special needs during a move, fill out and mail the Special Needs form in this handbook now.

i I ._ __ _ . _ _ . _ -- _ ---_ __. .- - _ - _ - _ _ _ , . _ _ _ _

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c. Where to Go (Relocation) !

The Evacuation Route Map in the ,

middle of this handbook shows the names of Reception / Relocation Centers. If you ara told to move, go to the Center l nearest your home. Traffic officers'will !

help you along the major routes on the .

Map. j When you arrive at the Center you f will be asked to give your name and other ,

details for the records. If you plan to ,

I go on from the Center, you will be asked [

where you are going and how you can be -

reached.

d. Children in School ,;

If you have children in school during an j i

emergency, please do not drive there or L

call the school. You will be told by i radio or TV what has been done to keep

, your children safe. The three possible l i

courses of action below can be taken at l schools. State and local of ficials will I recommend the one to follow. I i

1. Use the school as shelter. f

2. Bus the children to the Reception / i Relocation Center chosen for your l 1

children's school. '

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1 1.._, l

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l

{ ]O i si f.

3. Bus the children to another school outside the Zone until the end of the day and then to the chosen Center.

If the second or third course of action is followed, you should go to the Center 1

chosen for your children and stay there with them.

Some children may live in the Zone but go to a school outside it. They will be bussed from their school to a Center I where you can meet with them.

e. Special Needs If you have special needs, put them down -

now on the Special Needs form in this handbook. If you are older or physically disabled, you can be taken to a Reception / Relocation Center by emergency workers. Complete the form and mail it.

i If your needs are temporary, use the form or call your local emergency of fice. The number is listed inside the back cover of this handbook. Call if you need more copies of the form.

f. Boating or Camping l l

If you are boating or fishing, you will j be told of a Radiation Emergency through

! l

-- v : . u 9

. LR -

a marine or aircraft message. It will also tell you of a nearby dock where you may be taken out of the Zone to a Reception / Relocation Center. If you are camping or visiting, you will also be told of the emergency and directed to a Center.

g. Entry into the Zone You may have lef t the Zone before an emergency and find it blocked when you come back. The persons at road blocks can tell you what to do. If all members of your family understand the Plan in -

this handbook, they will also know what to do in an emergency.

S Where to Write or Call for Special Help j If you think you or your family might need special help during an emergency, do one of the following:

(1) Fill out the SPECIAL NEEDS form in this handbook and mail.

(2) Write a letter to describe your special needs and send it to THE CINCINNATI GAS & ELECTRIC COMPANY Emergency Planning -- Room 36 2 - A P. O. Box 960 Cincinnati, Ohio 45201 (3) Call your state or county emergency office listed

~~

below.

OHIO OHIO DISASTER SERVICE AGENCY:

CLERMONT COUNTY DISASTER AGENCY KENTUCKY KENTUCKY DIVISION OF DISASTER & EMERGENCY SERVICES:

CAMPBELL COUNTY DISASTER & EMERGENCY SERVICES:

PENDLETON COUNTY DISASTER & EMERGENCY SERVICES:

BRACKEN COUNTY DISASTER & EMERGENCY SERVICES:

M

+ %

PROPOSED LAYOUT '

OF EMERGENCY PLAN AS I" WOULD APPEAR IN APPROPRIA"E "ELEPHONE DIRECTORIES i

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D A

, d _

1 j WHAT TO DO IF THERE IS AN EMERGENCY l AT THE ZIMMER NUCLEAR POWER STATION l

These nuclear emergency procedures have been developed by the Cincinnati Gas & Electric Company in cooperation with the Disaster Services Agency, State of Ohio and Clermont County, Ohio; and with the Disasterand Emergency Services, Commonwealth of Kentucky, Bracken, Campbell and Pendleton Counties, Kentucky.

OWHAT WILL HAPPEN IN AN EMEROENCY? eWHA.* SHOULD YOU DO IF TOLD TO LEAVE THE If you live, work or happen to be visiting in the area AREA?

thawn on the map, this message may be helpful to

" "* they will be taken to the relocation center shown on the map.

If there is ever a problem at the Zimmer Nuclear Power Meet them there.

Station, state and local officials will decide, first, how serious -Pack only needed items (personal items, medical supplies, it is. Most problems will not place you in danger. If they children and infant tupplies).

decide there is an emergency, however, you may need to do -Lock your house.

something to protect yourself. _

eWHAT ABOUT OTHER THINGS?

OHOW WILL YOU KNOW IF YOU HAVE TO DO SSMETHING7 DO NOT take pets to the relocation center. Leave them at home.

If you live in the area marked on the map,you will be informed -Take only things you must have.

in the following ways. -Remember that police will patrol the area on the map to

-By special sirens protect what you have left behind.

By\special radios placed in homes By special announcements on radio & TV SHOW SHOULD YOU TRAVEL?

By emergency cars or trucks 1 Use your family car and take neighbors it you have room. )

OWHAT SHOULD YOU DO FIRST? Turn on your car radio.

]

-lf you have no ride, do not put out the sign from the handbook.

Turn on your radio or TV for advice. A ride will then be provided. Wait inside untilit comes.

Follow all advice carefully. -Use the closest route shown on the map to get to the

D3 NOT leave the area unless told to do so. relocation Center. Register there and ask for the next steps

D3 NOTuse your telephone unless absolutely needed- to take.

'D3 NOT call police or fire department for information.

CO NOT call your child's school or go there.

Special care will be taken of school children. DO NOT RUSH - Obey traffic signals and follow the Put in your window the "I have been notified sign'* from your dirsctions of police officers. l

" Circle of Safety" handbook. If you don't have the sign, tie a l large towell or other cloth on the front door or. mailbox.

For more information you should OWHAT SHOULD YOU DO lF TOLDTO TAKE SHELTER? read the " Circle of Safety" hand-

-Go inside your home or nearby building. Y ,

Stay insies. The Cincinnati Gas & Electr,c i Close all windows and doors. Company

-Turn off the heating and Cooling sysems. ,

-Wash your hands and face as soon as possible.

Cover up your food or put it in the refrigerator. Room 360A if you have a basement, take a radio and go there.

If you have no basement, stay away from doors and windows. P.O. Box 960 If you must go outside, go back inside as soon as you can. C,nc, i m nati, Oh,o i 45201

RELOCATION CENTERS T C D

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CLERMONT NORTHEASTERN JR. HIGH SCHOCL MILFORD JR. HIGH SCHOOL CLERMONT NORTHEASTERN MIDDLE SCHOOL 7 MILFORD MAIN MIDDLE SCHOOL 3

00 SHEN HIGH SCHOOL GOSHEN JR. SCHOOL l

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APPLICANTS' TESTIMONY REGARDING CONTENTION 23 2 Contention

( 23 2) Times necessary to take protective action during flood and tornado have been greatly in excess of estimated times because of the reactions j of a large segment of the population. (No plan provision.)

Testimony Prior to an emergency, information booklets entitiled " Circle of

, Safety" will be distributed to all residential and business addresses. This I

i booklet will contain specific evacuation instructions including designated evacuation routes. Instructions will also be included in telephone books distributed within the plume EPZ.

j During an emergency, prompt notification of the public will be achieved j by a combination of sirens and NOAA tone alert radios. This sytem will provide -

warning of the population and will direct them to other media for further instructions l

(i.e. the Emergency Broadcast System). This information will allow residents to take appropriate protective actions in a timely manner.

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. _1-- - - _-_. - . -_ _ _ _-__. - , _ -- _ - .

APPLICANTS' TESTIMONY REGARDING CONTENTION 24 1 Contention l

! 24. Within the EPZs of the Zimmer Station, inclusive of a 50-l mile radius, there a re inadequate medical facilities to afford the required bed spac'e, medical and para-medical personnel, requisite medication, screening, treatment and isolation of persons sustaining radiological injury; and the absence of adequate emergency materials, supplies, equipment and vehicles necessary for the transportation of injured persons, injured onsite and offsite, during a radiological accident.

Specifically 24 1) Clermont County and Cincinnati General Hospitals are the two Ohio hospitals which would provide inpatient treatment to radiologically injured individuals. The Central Ohio River Valley Association (CORVA) will provide guidance to those hospitals for development of disaster plans to include radiological emergency patient handling. Clermont County Hospital claims that it will treat radiological casualties and will institute procedures for radiation exposure treatment. Clermont County Hospital has 109 beds, but of that number would provide 45 beds by discharging ambulatory patients and transfer of others. Clermont County Hospital would transfer overage patients to Cincinnati General Hospital. Cle rmont County Hospital has not sought guidance f rom CORVA to the date of the filing of these revised contentions. Clermont County Hospital has not revealed its hospital plan for radiological treatment. CORVA will be disbanded April 1, 1982. Clermont County Hospital has two full-time radiologists and one rad io the rapis t, as a consultant, and two radiation monitors and sufficient decontamination equipment for minor radiation accidents. There is nothing to indicate that Clermont County Hospital has separate, segregated emergency facilities so that other patients are not contaminated. The plan as drawn and as to be implemented does not provide reasonable assurances that Clermont County Hospital can provide adequate facilities and personnel to treat radiologically injured individuals. (Clermont Plan, II-K, Med & Pub Health Sup p. II-K-1: IV, Letters of Agreement, Clermont Co un ty Hospital to Conover, January 21, 1981.)

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The Clermont County Hospital Radiological Assistance Plan has been available for some time. This plan was last updated in December, 1981 as a result of the November 18, 1981 exercise, and a copy of the current revision is attached. This hospital is prepared to receive patients with radiation contamination, and has designate.d a section of the hospital building to serve as a separate, segregated emergency facility. It sh>uld be emphasized that the Emergency Plan provides for potentially contaminated evacuees to be received, monitored, and decontaminated at the relocation centers. Only injured or the few, if any, severely contaminated individuals will be treated at the hospital. Those people that cannot be treated at the Clermont County Hospital, for whatever reason, will be transferred to Cincinnati

}

General Hospital or to other health ca re facilities identified in the i State of Ohio Nuclea r Power Plant Emergency Response Plan. There is _j also no requirement that only health facilities within the 50 mile EPZ be utilized to respond to a radiological emergency at Zimmer Station.

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t SATAVIA. CHIO 45103 513 732 8200 t b_ En. CLERf.'ONT COUNTY HOSPITAL 300 Mr. Fenneth Cenover January 21, 1981 Cle= ent Ccunty Disaster Services Icerc/

66 South Piverside Drive Batavia, Ohio 45103

Dear Mr. Concver:

This "Iatter cf Agreenent" confi=s eat, in de event cf a radiolecical e er-gency at de kh. H. Zi mer Nuclear Power Statien, the Cle=ent County Hospital (C"i) will treat radiological and eder casualties and institute procedures f = radiatien exposure treatment as des d bed in the Cler ent County Hospital Disaster Plan.

Se Atinistrater is responsible for de evaluatien and deterination of a possible disaster alert situaticn f= Cle=ent Cetmty Hospital. The physician me2er cf ea Cisaster C=rittee is rescensible for directinc de Mcal -

} s*'## functions of the COI Disaster Plan.

Sere is direct telephone line to the Cle=ent Cetref Sheriff, a radio receiver for ine: ring mergency calls and a Ecspital Staff Energency $11 List. Treatment of a large er.ber of casualties will be cocrdinated with Cincinnati Gercral Hospital. C rtericaricas between hospitals will be ever the Hamilt::n Cctr'.ty Disaster Radio Network.

Cle..:ent Cet=ty Hospital will reso::nd to de emergency by previding de follevine facilities, equianent, supelies and persennel:

- Wim1 advisories to Cle.=cnt County w m ia.e_it

- 2 full tire radiologists 1 radictherapist (censulting) radiological technologist assigned to ecver 2:ee shifts.

- 2 radiation renitors (sufficient decentrinatien equinnent f=

riner radiatien accidents)

- befs f= 109 patients, 45 cf which could be avamble fer an emergency.

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- n**bi staff of 107 (full and part-tine), 25 of *cn are only en Clernent County Hospital .Mical Staff and could be used.

- nursing staff of 1531 (full and cart *ime) <

l - KI stocked in hospital pbazmacy

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In additicn, Cle::ent C0t:nty Hoscital offers em:plete medical, surgical, and '

emergency care services. .

4 Very truly ycurs, f -

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l Sister Mary George Id-dr.istrat=r L Clem ent County Hospital .. ,

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Radiological Assistance Plan (RAP)

NUCLEAR DISASTER ALERT A. Equipment and Supplies - stored in Radiology Film Storage Room in Basement unless otherwise noted.

1. Monitoring / Survey Equipment

a. 2 - survey meters - located in Nuclear Medicine Room

b. 4 kits each containing

- 1 survey meter

- 2 air quality survey meters

- 6 pocket dosimeters Special Note - Meters are to be exchanged every six months (done in September).

Director of Disaster Services will send notices.

2. Disposable attire for personnel engaged in direct contact locations.

a. Jumpsuits or gowns

b. Surgical caps -

c. Masks

d. Gloves

e. Shoe covers . : -i ~

3. Directional Signs 4 Signal tape - 2 colors ..

5. 1.D. Cards' ,

6. Disaster name tags

7. Plastic sheets to cover carpet

8. Brown paper

9. Masking tape .

10. Black felt pens' "

11. Plastic waste bags

12. Bath towels

13. Soap, small bars ' ,l 'gu, g ,

14. Patient gowns -

15. Envelopes for valuables

16. Rope and stands

17. Instruction Sheets

18. Clipboards with instructions for each station

19. Flashlights - provided if alert is at night

20. Saw horses for blockade of orives if large number of persons can be expected to arrive at hospital B. Personnel Needed

1. Person to be assigned to detail at Armory Bob Morrison - Ext. 344 / Home Alternate Charles Shaeffer - Ext. 363 / Home i

)

Radiological Assistance Plan (RAP)

NUCLEAR DISASTER ALERT

- Page 2 -

B. Personnel Needed (cont'd.)

2. Physicians

a. Radiologists - John Parlin, M.D. - Ext. 244 / Home Jim Barnes, M.D. - Ext. 244 / Home

b. Emergency - Emergency Room - Ext. 214, 350

3. Administrator - Sister Mary George - Ext. 278, 303 / Home 4 Radiophysicist - Dr. James Keriakes -

5. Radiology Technologists

a. Gary Saunders - Ext. 244 / Home

b. Char Hand ey - Ext. 244 / Home

6. Nursing Service - Ext. 274

7. Out Patient - Ext. 352, 349

8. Plant Services - Ext. 295, 294, 249

9. Admis,sion. Registrar - Ext. 222 C. Ajencies Providing Emergency Advice / Coordination

1. Sheriff's Office - 732-2231

2. Civil Defense - 732-7235

3. Ohio Department of Health Radiological Health Unit (614) 466-1380 (office)

(home)

P.O. Box 118 275-7040 (beeper)

Columbus, Ohio 43216 Robert M. Quillin, Program Director '

4'. Radiation Emergency Assistance (615) 576-3098 or 3131 Center / Training Site (REAC/TS) 482 2441 beeper 241 Oak Ridge Associated Universities Oak Ridge, Tennessee (24-hour number)

5. U.S. Nuclear Regulatory Commission (312) 932 2500 799 Roosevelt Road Glen Ellyn, Illinois 60137

6. U.S Department of Energy (312) 972-4800 (duty hours)

Chicago Operations Office 972 5731 (off duty hours) 9800 South Cass Avenue Argonne, lilinois 60439

7. Joint Nuclear Accident Coordinating (505) 264-4667 Center (Nuclear Weapons Accidents)

Albuquerque, New Mexico t s t*z

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Radiological Assistance Plan (RAP)

NUCLEAR DISASTER ALERT

- Page 3 -

1. Alert A. In the event of a Nuclear Disaster Alert, the Hospital can expect to receive a c;fl from the Sheriff's Office or from Zimmer office.

1. PBX operator will relay message to administrator or her designee.

2. Administrator, or her designee, will confirm the message by a call to the Sheriff's Office (732-2231).

3. On confirmation, the Administrator will assign staff person to detail at the Armory (Armory Detail Person). -

4 Person assign to Armory Detail will serve as the laision between the Disaster Center and the Hospital.

a. Advise administrator of assigned telephone number,

b. Keep administrator informed as to status of alert and when to activate plan.

5. Administrator will call the' following and inform them of call:

a. Plant Services (Ext. 295)

b. Out-Patient Supervisor (Ext. 352)

c. Nursing Service (Ext. 274)

d. Chief of Radiology (Ext. 244) obtains supplies from storage 1) ll. Activation of Plan 4

A. Upon receipt of notice from Armory Mtail Person, the Radiological Assistance Plan (RAP) will be activated.

1. Administrator will advise the PBX operator to initiate the Plan by paging:

'" s . , . -

,"Codi RAP ,(add " Practice" for a drill) report to your station" three times. _

(Station - Out pat'ie'rit shower area for assignments and protective attire)

2. Air conditionMe'ntilation system will be turned offexcept- in ' Surgery.

3. Parking Lot No. 5 will be vacated by Plant Services.

4 Surgical Waiting Rooms will be vacated.

5. In the event of a real alert, the PBX operator is to call each office in Mercy Medical Office Building and advise the office staff of the alert putting them on notice of possibility of need to evacuate parking lot and to refrain from sending patients to hospital service departments.

1,

8. Traffic Control

1. Location - Traffic Control will be established at the junction of the driveways.

2. Staffing - 2 persons from Plant Services i 1 person from Nursing Service

A Radiological Assistance Plan (RAP)

NUCLEAR DISASTER ALERT

- Page 4 -

B. Traffic Control (cont'd.)

3. Equipment - 1 air quality radiological meter 1 survey meter 3 pocket dosimeters Supply of signal tape to affix to autos

a. Yellow - contamination

b. Red - illness or injury instruction Sheets (maps / sheet with directions to evacuation sights)

4. Erncedure

a. Nursing Service person monitors occupants of autos for presence of contamination,

b. If evidence of contamination is present, Plant Service person will affix yellow tape to windshield and route to Parking Lot No. S.

c. Occupants are asked if anyone has any evidence of physical injury or medical illness.

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. . nren [; r n....--tape to windshield and route to Parking Lot No. 5.

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d. If no evidence of contarnination is present and person (s) has no illness or injury

1) give instruction sheet on symptorns to watch for: -

2) route through Parking Lot No.1 back to highway;

3) if shelter is needed, advise person to listen to emergency broadcast radio station for locations.

e, if no evidence of contamination is present but person has physical injury or illness - route to Emergency Room.

C. Entrance '

1. Location _

Entrance to building will be the North entrance .to the Surgical Waiting Room in the connector between hospital and Mercy Medical- Arts Building. All persons are to remain in autos until called to doorway.

2. Staffing - 1 Security Officer to control traffic 2 Nursing Service staff persons to survey patients before permitting them to enter waiting room.

3. Equipment - 1 survey meter to be used by nurse outside entrance to waiting room 3 pocket dosimeters 2 changes of stripes of brown paper to cover plastic sheets.

Plastic sheets to cover carpet 1 roll of masking tape to tape plastic and paper in place 1 large waste can Supply of large plastic bags I.D. cards for patients who do not have one Pens I.'

Procedure

a. When notice is received from Armory Detail Person, Surgical Waiting Lounge is

Radiological Assistance Plan (RAP)

NUCLEAR DISASTER ALERT

- Page 5 -

l C. Entrance (cont'd.)

4. Procedure (cont'd.)

to be vacate'd. Doors between two rooms are to be closed.

b. Carpet is to be covered with sheets of plastic and stripes of brown paper.

c. One nurse should monitor patients outside entrance

1) If positive - fill out I.D. card and admit to Waiting Room.

2) If negative - route to secondary waiting area for discharge.

d. Nurse inside in waiting area has person remove shoes and directs him to Decontamination area. Observes patients having physical or medical illness for priority of care.,

e. Brown paper is to be changed at least once every 24-36 hours,

f. Corridor from Waiting Room to shower area should be mopped frequently; water should be changed frequently; bucket emptied into drain in shower room.

D. Decontamination

1. Location - The shower in the out-patient area will be used for decontamination - . .

of patients.

2. Staffing - 2 physicians:

a) radiologist, if available, for consultation and monitoring and treatment of victims b) emergency physician to treat patients 1 nurse to assist with patients who have physical injury or medical illness 1 clerk to complete checklist and disaster tags t , = t: , . 1 nuclear medicine technologist to do monitoring

3. Equipment - 1 survey meter used outside shower 1 survey meter used in treatment room- -- -

5 pocket dosimeters Disaster tags Checklists Black felt pens Plastic bags for clothes l i

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Envelopes for valuables Towels-Gowns Slippers ,

Soap I Rope and stands to block off corridor to Connector l

4. Procedure

a. Check I.D. cards for names then deposit cards in designated box to be kept for

.NRC or REMA inspection.

b. Shower patient

1) Inside shower room have patient remove clothes, place in large plastic bag

. . . . m Radiological Assistance Plan (RAP)

NUCLEAR DISASTER ALERT

- Page 6 -

D. Decontamination (cont'd.)

4 Procedure (cont'd.)

marked with patient's name and address. Leave bags in shower room.

2) Place valuables in envelope.

3) When shower is completed, have patient place towel in container in shower room. Dress in gown and slippers.

c. Outside shower room

1) Nuclear medicine technologist will obtain survey reading, fill out checklist and affix disaster name tag.

2) Nurse will triage patients for proper disposition a) Discharge - through Out Patient unit to exit near doctors' lounge, b) Minor Treatment - irito Out Patient treatment room 1.

c) Major Treatment * - to ER, Surgery or admission to appropriate unit.

Special Note - treatment of major injury or illness takes priority over decontamination. --

d) When wounds are being prepared for suturing, the physician should monitor the wound with survey meter to be sure wound is decontaminated before closure.

e) At this point - usual procedures are used for treatment and discharge _

of patients.

E. Vehicles

1. Emergency vehicles are routed to the loading dock for decontamination. They are to be washed inside and outside, surveyed and then released for use.

2. Private vehicles which are contaminated will be impounded. Drivers will* park these autos on grass north of hospital building. .s' .. - J ' . . . ;.

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F. Transportation j .. g , g ,;,, ,.

1. For transportation of discharged patients to a local shelter, call Armory Detail Person. Number ii assigned at time of alert.

G. All Clear .

The exercise could be short or long depending on the nature of the nuclear disaster. I The signal to terminate the exercise will be given by administrator to the PBX operator !

upon receipt of notice from Armory Detail Person at the Disaster Service Center. The PBX operator will announce -

"Dr. RAP, all clear" three times.

H. Personnel #- -

l Personnel from all stations will:

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i

! Radiological Assistance Plan (RAP)

. NUCLEAR DISASTER ALERT j - Page 7 - ,

i t

i H. Personnel (cont'd.)

i 1. Report to decontamination area to be monitored.

I j 2. Return dosimeters for- reading.

i

3. Remove contaminated clothing and shoer if needed.

4 Replace all equipment and supplies, i

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1 1 ,_ __._ ._. . _ _ . _ _ . . _ , _ _ , . _ _ _ _ _ _ _ _ _ _ _ _,_ __ ,.____ .__,_ _,_. __

APPLICANTS' TESTIMONY REGARDING CONTENTION 24 2 Contention 24 Within the EPZs of the Zimmer Station, inclusive of a 50-mile radius, there a re inadequate medical facilities to afford the required bed space, medical and pa ra-medical personnel, requisite medication, screening, treatment and isolation of persons sustaining radiological injury; and the absence of adequate emergency materials, supplies, equipment and vehicles necessary for the transportation of injured persons, injured onsite and offsite, during a radiological accident.

Specifically 24 2) Other than noted in pa ragraph 1 } above, no other information is presented by the Clermont Plan pertaining to Cincinnati General Hospital. (No plan provision.)

l Testimony No additional information is required by NLIRFG-0654 FEMA-REP-1.

The letter of agreement with Clermont County Hospital and the letter of agreement between CG&E and Cincinnati General Hospital fully describe Cincinnati General Hospital's role in an emergency response. -

Medical facilities in Ohio available for the treatment of ~

individuals involved in radiological accidents a re identified in the State of Ohio Nuclear Power Plant Emergency Response Plan (Figure II-K-3). Cincinnati General Hospital is one of those listed in this plan, and as an accredited hospital, is capable of handling radioactively contaminated patients. Additionally, Cincinnati General Hospital is the coordinating hospital fo r the Greater Cincinnati Hospital Council, which provides general emergency management and radio communications among the area hospitals during disasters.

110

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1 APPLICANTS' TESTIMONY REGARDING CONTENTION 24 3 Contention 24 Within the EPZs of the Zimmer Station, inclusive of a 50-mile radius, there are inadequate medical facilities to afford the required bed space, medical and pa ra-medical personnel, requisite medication, screening, treatment and isolation of persons sustaining radiological injury; and the absence of adequate emergency materials, supplies, equipment and vehicles necessary for the transportation of injured persons, injured onsite and offsite, during a radiological accident.

Specifically 24 3) Campbell represents that three hospitals have the capabilities to treat radiological injuries: St. Luke Hospital:

Cincinnati General and the University of Kentucky Medical Center (Lexington, Kentucky, approximately one hour travel time f rom Campbell County): in which each has submitted a letter agreement. Only the letter from St. Luke Hospital is presented in the plan. St. Luke

, Hospital does not indicate its bed capacity or how many beds would be available to hospitalize radiologically injured patients. This hospital has two radiology technicians and some monitoring equipment.

Isolation of contaminated patients is not indicated, nor is the ~

presence of separa te, segregated emergency facility. The plan as drawn and as to be implemented does not provide reasonable assurances that St. Luke Hospital can provide adequate facilities and personnel to treat radiologically injured individuals. (Campbell Plan, Annex H, Medical & Public Health p. H-2; Annex P, Int e r-Go ve rnmen t & Private Relations, letter, St. Luke Hospital to Flynn) .

I Testimony J

St. Luke Hospital's provisions for handling radiologically injured patients, including the establishment of adequate bed space in a separate, segregated portion of the hospi tal, are included in the hospital's disaster plan. Cincinnati General Hospital's capability to treat radiologically injured patients is addressed in the response to Contention 24 2.

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111

Center as well as other area facilities, describing their ability to receive radiologically injured patients is currently being acquired.

The radiological emergency plans provide for the monitoring and decontamination, if necessary, of evacuees at decontamination /

reception cente rs. Only the very few evacuees for which additional decontamination or medical treatment may be necessary are expected to be t ra nspo rted to the medical faci lities identified in the plans.

.1.12

APPLZCANTS' TESTIMONY REGARDZNG CONTENTION 24 4 Contention 24 Within the EP2s of the Zimmer Station, inclusive of a 50- I mile radius, there are inadequate medical facilities to afford the required bed space, medical and pa ra-me d i ca l personnel, requisite medication, screening, treatment and isolation of persons sustaining radiological injury; and the absence of adequate emergency materials, supplies, equipment and vehicles necessry for the transportation of injured pe rsons , .inj ured onsite and offsite, during a radiological accident.

Specifically 24 4) Other than noted in paragraph 3) above, no other information is presented by the Campbell Plan pertaining to Cincinnati General Hospital or University of Kentucky Medical Center. (No plan provision.)

Testimony Refer to the Testimony regarding Contention 24 2 and 24 3.

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i APPLICANTS' TESTIMONY REGARDING CONTENTION 24 6 Contention ;

24 6]. The life squads present in Clermont County, Ohio, have no training for the examination and determination of per-sons contaminated and to take required safeguards to exclude such individuals from non-contaminated members of the public; and the members of the respective life squads in the plume area of Clermont have no training or qualifications in rendering aid to individuals contaminated and individuals sustaining radiological injury. The members of the plume area life squads i in Clermont County may or may not respond as emergency resource i personnel based upon priority commitments to one's vocation and the need to assist one's family during the evacuation process.

The Clermont Plan in its implementation of providing volunteer life squads to assist and render aid to radiological injured and contaminated individuals provides no reasonable assurance that such volunteer will in fact volunteer one's services during an emergency. [No plan provision]. ;

Testimony The contention is based upon a misinterpretation of the ,

plan. The plan provides for other personnel, not life squads, -

to examine, monitor, segregate, and decontaminate, if necessary, potentially contaminated individuals. Life squad personnel do not staff decontamination / relocation centers for the general public, but provide standard emergency medical support during a radiological emergency as they would during other types of emer-gencies. These are functions normally performed by life squad e

personnel. Life squads routinely man vehicles during working hours. Mutual aid agreements presently in force provide for backup support for each life squad when they are unable to respond.

Volunteers are by their very nature dedicated and it is not unreasonable to assume that a large segment will perform the services during a radiological emergency at Zimmer to the extent i

they are able. In addition, the plan provides for additional support of emergency response organizations as necessary from i i

11s1 I

1 state and federal resources. Training for the transportation of potentially radiologically contaminated injured persons has been provided to two of the three Clermont County life squads designated to respond to the Zimmer Nuclear Power Station site (New Richmond and Moscow Life Squads). The third will be trained prior to operation of the facility.

Hans and Sell, Evacuation Risk - An Evaluation, EPA, 1974, is a study which examined a number of emergency situations and concluded that volunteers generally respond during natural and ma n-made disasters .

Alb

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APPLICANTS' TESTIMONY REGARDING CONTENTION 24.7 ;

Contention 24.7). The monitoring of evacuees by local police and fire personnel l at relocation centers within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of the evacuees arrival is inadequate l to screen, separate, and isolate contaminated individuals, providing exposure t by the contaminated person to the population at the relocation center. There are no provisions set forth and no implementation of training to police and fire personnel to properly monitor evacuees at relocation centers, to screen evacuees and isolate those contaminated or decontaminate such individuals or ;

the facilities for decontamination. There is no provision for monitoring of l persons present at relocation centers before such persons exit the premises.

(Clermont Plan, II-I, Protective Response, p. II-I-4; otherwise no plan provision.) '

1 t Testimony

, Methods have been developed to adequately screen, separate, and isolate l

potentially contaminated individuals from uncontaminated individuals. Specific training for the performance of these tasks has been provided to members of _

at least two fire departments and will be provided for all involved fire departments prior to comercial operation of the Zimmer Station. Such training is performed at the actual relocation / decontamination center designated for the specific fire department. Site specific information developed at the time of the training is incorporated into the procedures to assure operation of that facility as ,

a relocation /decontaminatio;i center. ,

All evacuees will be monitored on arrival and are not pe.niitted to proceed to the relocation center until they are screened and determined to be uncontaminated or have been decontaminated. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time limit for monitoring all evacuees is set by the guidance of NUREG-0654/ FEMA REP-1. Evacuees will be monitored as soon as possible, upon their arrival.

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i APPLICANTS' TESTIMONY REGARDING CONTENTION 24 9 Contention 24 9) Campbell County does not provide for any monitoring of plume exposed persons, e' x cept that persons transported by school buses who do not wish to go to a reception center will be decontaminated at Northern Kentucky University. The absence of any reasonable assurance that contaminated persons will be monitored and decontaminated, as necessary, fails to provide reasonable assurance that monitoring of persons and decontamination procedures will be implemented. (Campbell Plan, Annex F, Protective Actions, p. F-9-1.)

Testimony Provisions have been made and are outlined in the Campbell County Plan to monitor and decontaminate all evacuees and emergency workers and their equipment. Evacuees not planning to stay at the host county relocation centers will be monitored and decontaminated if necessary at Northern Kentucky University (Annex F, F-9-1; Annex E, E-2). Evacuees proceeding to the host county reception

~

centers will be monitored there and decontaminated, if necessary, at decontamination centers. The decontamination center in Grant County is located in the Grant County High School in Dry Ridge, Kentucky and the Boone County decontamination center is located in Connor High in Hebron, Kentucky. (Annex E-2, Annex L, Appendix L-1 & L-2.) Emergency workers and their equipment will be monitored '

and decontaminated at the Northern Kentucky University (Annex E, E-2).

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l APPLICANTS' TESTIMONY REGARDING CONTENTION 25 3 1

Contention

25. The monitoring devices selected and their placement offsite for the monitoring of releases, anticipated and accidental, of radioactive materials, including plume exposure in the event of accident, as to the location are inadequate to protect the health and safety of the population of Clermont County, Ohio, and as the same applies to the monitoring of releases into the Ohio River, and other sources of water for human consumption, as the same affects drinking water, plant and animal life of that waterway and area 4

within the plume exposure which are subsequently consumed by the population of the county; and the inability of such monitoring to adequately and timely inform the applicant and local and state agencies and related dissemination of such information to and for the protection of the public's health and safety.

Specifically 25 3) The Clermont County Board of Health and the Clermont County Cooperative Extension Service are jointly responsible for the monitoring and evaluation of the impact of radiation release upon county farm products and livestock and based upon such monitoring and assessment will institute protective actions pertaining to milk and livestock feed control. The plan provides no procedure and no procedure can be implemented with reasonable assurance for the protection of the public that livestock and dairy cattle within the monitoring range can be provided stored, closed feed, removed from pasturing, that facilities exist at the respective farm to remove livestock from field and house them and to store in sufficient quantity feed in closed containers, and to monitor that such protective agricultural practices are followed at the farm level. (Clermont Plan, III-A, County Agencies (Gen),

pp. III-A-3 and 10; otherwise no plan provision.)

Testimony Food, Water, Milk, and Livestock Feed Control is the responsibility of the Ohio Department of Health, and is described fully in the State of Ohio Nuclear Power Plant Response Plan,Section IV. The Clermont County l Board of Health and the Clermont Cooperative Extension Service are support agencies only in this function, and as such have no separate operating procedure.

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Additionally, provisions do exist at the State level to monitor and take appropriate actions for all farm products, including those from livestock and dairy cattle. Monitoring will be performed on products intended for human

! consumption at various stages of production up to and including just prior i 116

to being made available to the public. Therefore, although all attempts will be made to house and provide stored feed for farm animals, failure to do so does not imply an inability to protect the health and safety of the population of Clermont County.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 25 4 Contention

25. The monitoring devices selected and their placement offsite for the monitoring'of re' eases, anticipated and accidental, of radioactive materials, including plume exposure in the event of accident, as to the location are inadequate to protect the health and safety of the population of Clermont County, Ohio, and as the same applies to the monitoring of releases into the Ohio River, and other sources of water for human consumption, as the same affects drinking water, plant and animal life of that waterway and area within the plume exposure which are subsequently consumed by the population of the county; and the inability of such monitoring to adequately and timely inform the applicant and local and state agencies and related dissemination of such information to and for the protection of the public's health and safety.

Specifically 25 4) There is no provision for the monitoring of milk produced in the EPZs and transported in bulk to a processing and bottling facility for distribution to retain groceries and subsequent human consumption. (No plan provision.)

TESTIMONY The Ohio Department of Health (0DH) is the responsible agency for milk control and dairy animal protection in Ohio.

ODH maintains a list of all Grade A milk producers in Clermont County and a list identifying shipping locations for each producer. ODH maintains contact with milk producers through local extension services and local health departments. ODH maintains contact with processors through the Ohio Dairy Products Association, which can advise ODH of any changes in location of standard shipments of milk at the time of an emergency, and develops systems to sample and monitor milk supplies. Locations of all milk producers are plotted on a map enabling ODH to identify which farms would most likely be affected by a release from Zimmer. Contact with milk producers and processors may also be made through Milk Managenent Inc., which reprecents the interests of both the producers and processors.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 34 Contention 34] The proposed Kentucky and Campbell County radiological j response plans invalidate themselves as responses to the i requirement for plans in 10 C.F.R. & 50.33(g), 10 C . F . R . &

50.47(a), (b), 10 C.F.R. Part 50, Appendix E, and NUREG-0654 4

because they repudiate their own use during an emergency. The Campbell County plan (p. V, Plan Organization) contains the following statement: "During an emergency, Standard Operating Procedures (SO Ps ) , developed from the plan, will be employed to respond to the emergency rather than this planning dosument" .

This statement is essentially repeated in the Campbell County Basic Plan, Appendix 8, p. VII-8-1, and twice in the Kentucky plan: Plan Organization, p. VI and Basic Plan, Appendix 5, p.

5. SOPS are not included in the plans and have not been submitted separately.

Since the plans disavow themselves and establish SOPS as

the sine qua non of emergency planning during an emergency, and since no SOPS are contained in the proposed plans or have been otherwise submitted, the people of Mentor, of Campbell County, -l and of Kentucky have no plan to protect their health, safety,

and interests during a radiological emergency at the Zimmer Plant. As they stand, the so-called plans are, by self-description and by objective inspection, simply statements of intentions or, at best, plans for plans. To consider them in any other light would deny Mentor its right to make a timely evaluation of plans that would actually be used during an emergency those that, if they exist, are hidden in the undisclosed SOPS.

Testimony The purpose of the radiological emergency plans is to identify the various groups and authorities that will be involved during an emergency, and then to organize; out not to describe in detail, the response of and the interrelationship among these different entities.

Accordingly, having set forth the specific kinds of actions that must be taken, the plans then assign responsibiity (primary, secondary, etc.) for these actions to those groups or l'L1 :

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authorities that have been identified as playing an emergency j response role. In this way, the plan assures that the many 1

l groups involved in such an operation will 1) receive a timely alert, 2) be called upon to act when and if their participation

is needed, and 3) act cooperatively, without duplicating or l hindering each other's effort.

l An equally important aspect of the plans is that they establish lines of communication that are logical and consistent with the way in which responsibilities have been delegated.

This function is essential to a timely, coordinated response.

In addition to organizing an emergency response, the plan pro-vides for logical lines of communication to assure the flow o>t l

information needed to activate personnel and make timely deci-sions. The plan provides for information to be transmitted without delay to the authorities responsible for these deci-sions. It thus ensures that emergency response groups under the jurisdiction of these authorities can be informed of decisions that will determine their course of action, as described step by step in the written procedures.

NUREG-0654 FEMA-REP-1 states under the title " Content of Plan s " that; " applicable supporting and reference documents and tables may be incorporated by reference and appendices should be used whenever necessary. The plans should be kept as concise as i

possible. The average plan should consist of perhaps hundreds of pages, not thousands. The plans should make clear what is to .

be done in an emergency how it is done and by whom."

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Procedures which are derived from the plan and are consis-tent therewith are used to support the planning concepts and are used to implement certain planned responses and provide the more detailed steps necessary for some actions in suf ficient detail to provide unambiguous guidance in a wide range of situations.

Iloweve r , it must be kept in mind that the plan already embodies the concepts and policies to be implemented in the procedures.

This concept of plans and detailed procedures is entirely consistent with the Nuclear Regulatory Commission regulation.

Appendix E, 10 CFR Part 50, Section V recognizes the role of procedures in response to an emergency. Of course, state and local authorities have the updated copies of various plans available for reference during an emergency if needed. -

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j APPLICANTS' TESTIMONY REGARDING CONTENTION 35

Contention

35. Although the 50-mile ingestion oathway for the Zimmer Station EPZ includes about 700 square miles of southeast Indiana, there are no radiological emergency plans by or on behalf of the State ;

of Indiana or the affected local Indiana governments. This omission i endangers the health, safety, and interests, not only of the people of l Indiana, but also of the people of Mentor, Campbell County, Kentucky, and Ohio, and is in violation of 10 C.F.R. Pa rt 50, Appendix E, 10 l C.F.R. 50.33(g), 10 C.F.R. 50.47, NUR EG-0 6 54 / FEM A-RE P-1, II-J-ll, p.

79 (and all other criteria fo r state plans which are related to ,

ingestion pathway planning). ;

The people of Mentor, of Campbell County, and of Kentucky (and ,

of Indiana and Ohio) do not live in a vacuum; political boundaries are of no significance here. Parts of Kentucky (including Mentor),

Indiana, and Ohio form a tri-state area within which there is <

production, distribution, and consumption of milk and other foodstuffs (

with little or no regard to point of origin. The people of Mentor buy '

their food in this tri-s tate ma rket and must not be exposed to the ;

hazards of contaminated food from the unprotected Indiana part of the j 50-mile EPZ. Simple humanitarianism extends this concern to all people who might be similarly exposed. ,

j Testimony i

The Indiana Radiological Emergency Response Plan for Fixed Nuclear Facilities, prepared by the Indiana Department of Civil !

Defense & Emergency Management, provides ingestion exposure pathway planning for all nuclear power plants adjacent to the State of l Indiana, including the Wm. H. Zimmer Nuclea r Powe r Station. Such I planning includes the use of agents of the Indiana State Board of !

Health to obtain samples of foodstuf fs and consumed items, for their analysis, the interdiction and disposal of contaminated items, and the I provision of uncontaminated supplies of drinking water and foodstuffs.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 36 I Contention 36 I) The proposed system for prompt notification of the public (Campbell County plan: Annex C, I-A-1, p. C-1, IV-C, p. C-3, l Appendix C-5) is' inadequate and a burden to the people in that the '

siren system is designed to warn only 40% of the people within the 10-mile EPZ and has not been tested to ensure that it will achieve that design objective in any or all weather conditions for people outside !

or inside their homes during all their various activities; the radio

system will not serve people who a re outside their homes, farmers in I

the field, or people in their automobiles and th e integrated siren and i

radio system is not adequate to protect those with hearing or sight impairments or those who operate or are near loud or noisy equipment and, being dependent upon electricity, will not function during periods of electric power outage.

Testimony The statement that the siren system is designed to warn only

~

40 percent of the people within the 10-mile EPZ is false. The Prompt

Notification System design report states: "Within 5 miles of the l station, the recommended alerting system includes 8 sirens covering approximately 40 percent of the popula tion. " In addition to the sirens, in-home NOAA weather radios will be made available to all f households within five miles of the station. In the 5-10 mile range the population will be covered by either sirens or in-home NOAA weather ra d i o s . The Prompt Notification System was designed with concideration of a wide range of weather conditions. The Prompt i

i Notification System will be tested and evaluated by the Federal Emergency Management Agency (FEMA) prior to final approval of the ,

j system. While there are cases such as fa rmers in the field, people in their automobiles or people who a re outside their homes where notification cannot be guaranteed , the system as designed meets the :

design objective of direct coverage of essentially 100 percent of the f

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popu6ve mKlles og the sKte. In any event, the l integrated test of the PNS will determine the acceptability of the l -system as installed, and corrective actions will be taken based on the results of the integrated tests.

1 People will not be compensated for use of the NOAA weather rad ios; use of these radios is completely voluntary. Special arrangements will be taken to assure that those with hearing or sight j impairments will be capable of being notified by- the system. For l

example, it is anticipated that hearing impaired persons will be

provided with in-home NOAA weather radios which notify by virtue of a flashing light as opposed to a tone. Both the in-home NOAA weather radios and the sirens a re battery equipped, hence, they a re capable of functioning during electrical power outages.

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APPLICANTS' TESTIMONY REGARDING CONTENTION 36 K Contention 36 K) Provisions for the monitoring, control and regulation of public water suppl'ies, or for the availability of uncontaminated water to the public, before and during a radiological emergency (Campbell County plan:

Annex D. Appendix D-3; Annex F, G, p. F-8, pp. F-11, F-12, and F-13, Appendix F-12, IV p F-12-1 Annex H IV-B, p. H-2 Annex P, Appendix F) are not adequate to protect the health and safety of the people of Mentor or for a large population within the 10 and 50-mile EPZs in Kentucky because there is no radio comunications system between the Zimer plant or state or local response agencies and the water treatment and supply facilities; the water treatment and supply facilities do not have the equipment or trained personnel for continuous monitoring of water before and during a radiological emergency; the present plans are too undeveloped and too clumsy and time-consuming to ensure that prompt and appropriate protective action can be taken; and, further, the people of the City of Mentor and a large population within the 10 and 50-mile EPZs, who receive their water from treatment and supply facilities that are situated near and are not unlike those of the City of Cincinnati, have not received consideration and potential protection similar or equal to that given the ,

people of Cincinnati as evidenced by the recent settlement between the applicant '

and Cincinnati in a matter of radiological protection.

Testimony -~

Provisions for monitoring, control, and regulation of public water supplies are adequate to protect the health and safety of the people of Mentor and the population of Kentucky within the 50 mile ingestion pathway EPZ. The assertion in this contention that there is no radio communications system between the Zimmer plant or State or local response agencies and the water treatment facilities is false. Two-way radio communications exist between the Zimmer Station control rocm, and the three nearest water intake and treatment facilities located downstream from Zimer Station on the Ohio River. Specifically, 2-way radio comunications will exist between ZPS-1 and the City of Cincinnati, Kenton County and Newport water works.

Continuous monitoring for radioactive isotopes in drinking water l 1s neither required nor necessary. Based on the average speed of the Ohio l

River, there would be a period of about ten hours from the time of any release i

l'Z7 1

from Zimmer Station to the time it reached the nearest water works intake on the Ohio River. Discharges from the Station are monitored. This allows more

, than adequate time for notification of the appropriate water works to take any required protective action.

! The Kentucky Department of Natural Resources and Environmental Protection (DNREP) - Division of Water Resources is capable of sampling water supplies. Analysis may also be performed by a private testing facility or by Federal contractor laboratories through the Department of Energy. DNREP maintains files and data on the sources of all area water supplies which i are readily available during an emergency.

Immediate supplies of " uncontaminated" water are not necessary when water intakes on the Ohio River are closed since water works have reserve -

storage capacity and can continue to supply water. In addition, during periods of severe drought and in situations when flooding renders ground water sources unusable, State organizations have gained extensive experience in supplying water from alternate sources.

The people of the City of Mentor, who receive their water from the Newport Water Works, are adequately protected from exposure to contaminated water supplies by the provisions stated above.

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UNITED STATES OF AMERICA j NUCLEAR REGULATORY COMMISSION i

j In the Matter of )

5 I j The Cincinna'ti Gas & Electric ) Docke t No . 50-358 j Company, et al. )

! )

J (Wm. H. Zimmer Nuclear Power )

l Station) )

j l

f CERTIFICATE OF SERVICE l

1 l I hereby certify that copies of:

1 l 1. Applicants' Testimony Relating to Emergency Planning

( Contentions, dated January 15, 1982 1

j 2. Professional Qualifications of Greg ' C. Picke

)

3. Professional Qualifications of Arthur H. Badger

~

4. Professional Qualifications of Larry S. Weiss

) have been served upon the following by deposit in the United 1

States mail this 15th day of January, 1982:

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i

Judge John H. Frye, III Chairman, Atomic Safety l Chairman, Atomic Safety and and Licensing Board Licensi.19 Board Panel U.S. Nuclear Regulatory U.S . Nuclea r Regulatory

} Commission Commission j Washington, D.C. 20555 Washington, D.C. 20555 i

} *Dr. Frank F. Hooper Charles A. Barth, Esq.

J Administrative Judge Counsel for the NRC Staff

! Atomic Safety and Licensing Office of the Executive

! Board Legal Director

! School of Natural Resources U.S. Nuclear Regulatory

,- University of Michigan Commission j Ann Arbor, Michigan 48109 Washing ton , D.C. 20555 i

i j

Overnight delivery service

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Dr. M. Stanley Livingston Mr. Chase R. Stephens Administrative Judge Docketing and Service 1005 Calle Largo Branch Sante Fe, New Mexico 87501 Office of the Secretary U.S. Nuclear Regulatory Dr. Lawrence R. Quarles Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Chairman, Atomic Safety Commission and Licensing Appeal Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory

- Andrew B. Dennison , Esq. Commission Attorney at Law Washington, D.C. 20555 200 Main Street Batavia, Ohio 45103 David K. Martin, Esq.

Assistant Attorney James R. Feldman, Jr., Esq. General 216 East Ninth Street Acting Director Cincinnati, Ohio 45202 Division of Environmental Law

- John D. Woliver, Esq. Office of Attorney Clermont County General Community Council 209 St. Clair Street Frankfort, Ken tucky 40601

~~

Box 181 Batavia, Ohio 45103

- George E. Pattison, Esq.

*Deborah Faber Webb, Esq. Prosecuting Attorney of 7967 Alexandria Pike Clermont County, Ohio Alexandria, Kentucky 41011 462 Main Street Batavia, Ohio 45103 William J. Moran, Esq.

General Counsel The Cincinnati Gas &

Electric Company P. O. Box 960 Cincinnati, Ohio 45201 1

I Mark J. @6tterhahn Ove rnigh t Delivery Service

Hand Delivery 1

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) 1 PROFESSIONAL QUALIFICATIONS !

{ GREG C. FICKE

] THE CINCINNATI GAS & ELECTRIC COMPANY i

My name is Greg C. Ficke and my business address is 139 l East Fourth Street, Cincinnati, Ohio. I am presently employed by j The Cincinnati Gas & Electric Company.

i l I graduated from Miami University in 1974 with a Bachelor

]

] of Science Degree in Engineering Physics. I received a Master of l

j Science Degree in Nuclear Engineering in 1976 from Ohio State University. I have attended evening classes at the University of Cincinnati since 1978 and am pursuing a Master of Business i

j Administration Degree.

I j From March 1976 to August 1977, I was employed by Bechtel Associates Professional Corporation as an engineer. During this period, I worked on various assignments in the areas of environmental

analysis of radiological releases, in-plant exposure to airborne

! radioactive materials, and meteorological data analysis.

j I have been employed by The Cincinnati Gas & Electric i

f Company since August, 1977 as an engineer in Licensing and

) Environmental Affairs Department. In this capacity, I have been l,

responsible for environmental radiological monitoring programs and

[ emergency planning for the WM. H. Zimmer Power Station.

i i I have attended various professional development courses j during my employment with Bechtel and CG&E including Bechtel Power i

f Plant Design Course; FEMA Interagency Course in Radiological l Emergency Response Planning for Fixed Nuclear Facilities; General j Electric Company BWR Training Center Design Orientation Course and University of Cincinnati Hospital Preparation for the Management of I

Radiation Accidents.

4

I am a member of the American Nuclear Society and a registered Professional Engineer in the State of Ohio.

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PROFESSIONAL QUALIFICATIONS ARTHUR H. BADGER SENIOR COMMUNICATIONS ENGINEER THE CINCINNATI GAS & ELECTRIC COf@ANY My name is Arthur H. Badger. I have been employed by The Cincinnati Gas & Electric Company since 1965. I presently have the title of Senior Communications Engineer. I have a Bachelor of Science in Electrical Engineering from the Lawrence Institute of Technology.

Prior to my employment with CG&E, I was associated with

. Motorola Incorporated, Motorola Communications and Electronics, Communications Service Company, and the City of Royal Oak, Michigan.

My principal responsibility is to manage the Communications Group of the General Engineering Department. This involves the study of communications requirements of all departments within the company, and the engineering of communications systems to fulfill the Company's needs. To fulfill this responsibility requires that I have technical knowledge and experience in the fields of radio wave propagation, radio and electronic circuitry and systems, communications transmission theory, signal measure-ments, antenna theory, electroacoustics, optics, and related disciplines.

?

The various modes of electronic communications that I am j experienced in include two-way radio, microwave, telephone, l teletype, data, television, and facsimile. I have 35 years l t

experience in the design, application, licensing, and i l maintenance of systems of this type. I also have extensive j t

knowledge regarding federal rules and regulations, and also !

! standards and codes as they apply to the design and operation of f f i t

these systems.

My responsibilities relating to the Zimmer Nuclear Power ,

f I

Station have included the design and implementation of f L

< communications systems using two-way radio, microwave, data j facsimile, telephone, teletype, and paging equipment used for ;

] _

} in-plant and of f-site applications.

i I am a member of the Utilities Telecommunications Council j and Chairman of its Nuclear Regulatory Commission Task Force. I [

an also a member of the Institute of Electrical and Electronics l

Engineers, j

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PROFESSIONAL QUALIFICATIONS Larry S. Weiss Project Engineering Manager Stone & Webster Engineering Corporation My name is Larry S. Weiss. My business address is Stone &

Webster Engineering Corporation, 250 West 3 4th Street, New York 10119. I am Project Engineering Manager responsible for all radiological emergency planning in Stone & Webster's New York office. This position involves the direction of emergency planning ef forts for three states, eight counties and many muni-cipalities, preparation of nuclear station emergency plans, including the emergency plan for the Wm. H. Zimmer Power Station.

I graduated from Cooper Union with a B.E. in Mechanical Engineering and from Carnegie Mellon University with a M.S. in Mechanical Engineering. I also graduated from the Naval Reactor's Nuclear Power School which is equivalent. to a M.S. in nuclear engineering.

Prior to my employment at Stone & Webster, I was affiliated with the Westinghouse-Bettis Atomic Power Laboratory as Super-visor of Plant Engineering. In that capacity, I was responsible for nuclear operating, maintenance and test procedures for a number of classes of submarine reactor plants. Additional responsibilities included development of emergency core cooling system operating procedures, resolution of operating problems and unusual occurrences and evaluation of the TMI accident. I also served as a Senior NSSS technical field representative. In

that position I was responsible for the safe conduct of submarine nuclear power plant refuelings, overhauls and test programs. During this work I was a qualified radiation worker, I participated in radiological emergency and nuclear accident casualty control drills.

I joined Stone & Webster Engineering Corporation in March 1980 as a Consultant in the Power Division. I have attended a 1

l workshop on state and local government emergency response plans 1 and preparedness for commercial fixed nuclear facilities and e

other workshops and conferences related to emergency planning.

I have been extensively involved in emergency planning efforts for nuclear power facilities and related state and local emergency planning efforts and support thereof.

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ML20040B126

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