ML20038C196

Parents Concerned About Indian Point Contentions.Certificate of Svc Encl

ML20038C196
Person / Time
Site:	Indian Point
Issue date:	12/02/1981
From:	ECIPARCO, PARENTS CONCERNED ABOUT INDIAN POINT
To:	Atomic Safety and Licensing Board Panel
References
*EP-24, *EP-43, *SD-44, ISSUANCES-SP, NUDOCS 8112100249
Download: ML20038C196 (7)

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. UNITED STATES OF AMERICA 7 NUCLEAR hEGULATORY CCMMISSICN ATOMIC SAFETY AND LICENSING 30ARD 00tMETED Before Administrative Judges '? 'M Louis J. Ca r ter, Chairman Dr. Oscar h. Paris '81 DEC -8 P2:31 Mr. Frederick J. Shon g

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In the' Matter of  : Docket Nos: 'H

. CNaolidated Edisnn Company of hew Yor k ! h-h

og (Indian Point Unit 2) *

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Power Authority of the State of New York *

,i(Indian Point Unit 3) *

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3 I CONTENTICNS OF '

%,"A 7d(%rer1981x PARENTS CONCERNED ABCUT INDIAN POINT /, ' 9

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P'arents Concerned About Indian Point, on behalf o its members and their children livin6 within the fifty mile ingestian exposure pathway Emergency Planning Zone, respectfully submits the following contentions:

I. Children within the ten mile plume exposure pathway Emergency Planning Zone are particularly susceptible to the physical effects of radiation and to the psychological ,

j trauma of a disaster, and are not adequately protected by the Radiological Emergency Response Plan.

l l BASES l 1) Ihe radiation dose absorption rate for children is significantly higher than for adultc, but correspondingly heightened protective measurea have not been designed for then.

2) Fami-lies residing within the ten-mile EPZ have been given no information or instructional brochures. To be effective, emergency planning information must..be.widely dis-seminated, extremely detailed, and avr.ilable in several languages.

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3) There is no financis11 commitment on the part of local government or the Nuclear Facility Operators to pay for the dissemination of emergency plannin6 information.

Without such information, parents will not be able to protect their childran.

4) If a nuclear acciden't occursekhile children are home but parents are not, the children will become part of the " transportation dependent populatinn." The children would be expected to walk up tc a mile to a bus stop and wait outside, possibly at the height of radiation exposure, to be evacuated by bus.

5) Children whose parents do not have cars will be part of the " transportation dependent population." These children will be expected to walk up to a mile to a bus' stop and wait outside, possibly at the hei'd ht of radiation exposure, to be evacuated by bus.

6) The buses planned to be used to evacuate the transportation dep'endent population are the same buses which will be used first to evacuta schools. Thus, any pre-schoc; children or home-bound children who are dependent on public transportation will be required to wait an undetermined amount of time, which could be several hours, at a time when speedy evacuation of the affected area will be crucial.

7) There are not enough school buses to effect a timely evacuation of all school children.

8) Bus diivers from areas outside the ten-mile EPZ will be called on to enter the EPZ to evacuate school children but there is no way to assure their co-operation.

9) The Radiological Emergency Response Plan does not require adequate trained staff on ouses, at school reception centers, or at congregate care centers to handle the psycho-logical trauma which children will undergo l.in a nuclear emer6ency. Frantic, uncontrollable behavior may hLmper the entire emergency response effort.

10) Voluntary participation of school personnel in an emerdency is depended upon and should not be. Teachers, adviinistrators, and staff will have their own family concerns to attend to.

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11) Voluntary participation of bus drivers is depended upon and should not be.

12) School bus drivers are known to be difficult to locate when not on duty and thus cannot be counted on to drive buses during an evacuation. At the very least, lo-cating bus drivers will add time to the evacuation procedures.

13) School persannel have no particular radiatinn disaster training and thus are ill equipped to become emer-gency workers in such a situation.

14) Bus drivers have no particular radiation disaster training and thus are ill equipped to become emergency workers in tuch a situation.

15) School reception centers and congregate care centers are not equipped with any emergency supplies.

16) If a nuclear emergency occurs during after-school hours, many children will be at publicly and privately sponsored I cultural and athletic pursuits such as music, ballet, scout meetings, and sport practice. Since there are no instructions to parents regarding this eventuality, and no provisions in the emergency plans, the confusion which will result as parents, children, and after-school supervisors try to cope will hamper the emergency response effort.

17) The notification system depends entirely on hearing:

hearing sirens or other media announcements. The children, especially the babies, of deaf parents will be at a disadvant-age and will not be adequately protected.

18) There are children within the 10 mile emer6ency planning zone who take special medication. If they are forced to evacuate without a supply of their medication, serious impairment to their health could result.

19) There are handicapped children within the 10 mile emergency planning zone who are left hone alone for various periods during the day. These children would be unable to evacuate by themselves.

20) The Radiological Emergency Response Plan calls on the resources of communities outside the 10 mile EPZ to help in the evacuation efforts. Local officials may need those resources to implement local emergancy plans which are being

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developed in response to public pressure.

21) The direction that operators of day care centers "have the responsibility for developing their own plans for caring for--their residents in the eventrof a radiological emergency" is totally inadequate to protect the lives and health of young children, and'the unco-ordinated efforts of day care center operators could impede the orderly flow of evacuation.

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22) Many special institutions within the 10 mile EPZ will have extraordinary problems, such as the Asthmatic Children's Foundation, where over 30 children in permanent residence will be in greater danger due to the stressful requirements of a nuclear emergency.

II. Children outside the 10 mile EPZ are particularly susceptible to the physical effects of radiation and to the psychological trauma of a disaster and are not adequately protected by the Radiological Emergency Response Plan.

i. BASES

1) The radiation dose absorption rate for children is significantly higher than for adults, but correspondingly heightened protective measures have not been designed for them.

2) There is no plan for attending to the psychological l needs of children outside the 10 mile EPZ who will be trauma-

! tized by perceiving a large scale nuclear emergency.

3) Families residing outside the 10 mile evacuation planning zone are likely to take their own protective measures i to insure the safety of their children. These measures may i include self-evacuation which, carried out in an ad hoc faehion, could hamper the evacuation of those within the 10 mile radius.

4) Advance planning of likely contingencies must be formulated to protect children both within and without the 10 mile EPZ.

5) Families residing outside the 10 mile EPZ havo been given no information or instruction as to how to protect their children from the possible ingestion of radiation. To be i

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effective, emergency planning information reqarding the ingestion of radiation-contaminated food and water must be widely disseminated, extremely detailed, and available in several languages.

6) There is no financial commitment on the part of the state or the Nuclear Facility Operators to pay for the disraemination of emergency planning information.

7) Special institutions outside the 10 mile EPZ will he.ve special problems in dealing with a nuclear emergency.

The resources of Blythedale Children's Hospital and the New York School for the Deaf, for example, will be staained as frantic parents try to make arrangements for their children, and as institutional staff are distracted by their own parantal concerns. .

III. Adequate consideration has not been given to parental and child behavior and to family decision making patterns in the emergency planning process.

BASES

1) Panic will ensue when parents and children, at different locatinns, cannot communicate with each other.

l 2) Parents are expected, under many circumstances, to evacuate withos their children. Parents are unlikely to i leave the area without their children. Particularly severe problems are likely to ensue when parents who are working outside the 10 mile radius but whose children are within the 10 mile radius at the time of an accident, return to the

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i area in order to evacuate as a family unit.

3) Parents will attempt by any means possible to get to their children. They will converge on schools, causing traffic congestion, confusion, and a delay in the evacuatinn process.

4) Most parents will not train their children in emergency procedures.

5) Children who have been informed of the proper l

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emersoney procedures cannot be relied upon to carry them out without guidance. Thus, children who are at home with-out parents or caretakers will not be able to carry out an evacuation (i.e. , get to the designated bus stop) on their own.

6) The only way to overcome parents' natural impulse to flee with their children, to forestall panic, and to insure an orderly evacuation is to hold frequent diills and to disseminate emergency planning information on a large scale.

7) There is no financial commitment to conducting any drills.

8) Frequent drills, although essential to the success of an evacuation, would be very costly, damaging, disruptive, and traumatic, especially to children.

9) children should not be subjected to the emotional trauma and potential physical harm of radiological emergency drills, but without such drills, parents, children, and dmergency personnel cannot be expected to perform adequately during a real emergency.

IV. ibe physical and psychological environment of children will be improved by permanently shuttin6 down the Indian Point Nuclear Power Station.

BASES 1.) The risk of an accident with a potential for offsite releases of radiation, core degradation, and/or loss of containment integrity will 'oe significantly reduced by cold shut down of units 2 and 3.

2) Parents, teachers, doctors, and other caretakers of children feel anxiety because of the continued operation of Indian Point. These anxieties are communicated to children and would be significantly reduced by cold shut down of Units 2 and 3.

3) Workers in the plant who are parents or potential parents are exposed to unacceptible levels of radiation due to operational and management practices at the plant. These workers are at risk of disease and genetic will be reduced by damage to their offspring, These risks shut down of units 2 and 3.

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.- UNI 2DD STATES OF AMERICA -

NUCLEAR. REGULATORY COMMISSICN 3EFORE THE ATCMIC SAFETY AND LICENSING SOARD g Louis J. Carter, Chairman ' MC Oscar H. Paris. l Frederick J. Snon

'81 DEC -8 P2:3 In the Matter of  !* Docket Nos.  ::sETAFf

' cG SERVICE Consolidated Edison Company of hT Inc. .:'jRANCH (Indian Point Unit 2) l

'[ [h Power Authority of the State of hT (Ugjt ! J

• CERTIFIC ATE OF SERVICE I hereby certify that on the 2nd day of December I caused a copy of the foregoing contentions to be hand delivered to the following:

Louis J. Carter Counsel for NRC Staff t CM Sd

US NRC AS & L3 US NRC Washington, D.C.

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g gy f 3 ri 5t Washington, DC 205;5 '

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Dr. Oscar H. Paris Mr. Frederick J. Shon US NRC US NRC, AS & L3 M V. A lfW J O'Ib'I AS & LN Washington, D. 20555 *Vfdh. tv Gr ec Washington, DC 20555 # '""

3 rent L. 3randenburg Ms. Joan Holt NYPIRG O p 'h Con Ed Co of NY, Inc 5 Seekman Street '*

4 Irving Place NY, NY 10038 M, E 10003

,9 gg Ezra 31alik bham Charles Mailkish Steve Leipzig 'V.1W 2 % Fu ( N M p  :

The Port Authority NYS Attorney General's Office beh m n ^^l NY & NJ Two World Trade Center / M'l One World Trade Cen ter NY, hT 10047 W , E 10048 Westchester Pepple's Action Coalition West 3 ranch Conservation P.O. Box 488 Association wnite Plains, New York 10602 443 3uena Vista Road Alan Latman New City, h7 1095e 44 Sunset Drive Andrew S. Roffe Croton-on-Hudson, NY 10520 New York State Assembly Albany, h7 12248 Marc. L. Parris County Attorney, Rockland County Greater NY Council on 11 New Hempstead Road Energy c/o Corren New City, New York 10956 New York University St y nt St New York City Audubon Society Mr. Geoffrey Cobb Ryan 71 W. 23rd St., Suite 1828 Stanley Kimberg NY, LT 10010 NYS Energy Office 2 Rockefeller S tate Plasa Eon. RuN ;)wenwr-

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