ML20039D022

Contentions of Parents Concerned About Indian Point

ML20039D022
Person / Time
Site:	Indian Point
Issue date:	12/10/1981
From:	AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
CONTENTION, ISSUANCES-SP, NUDOCS 8112310226
Download: ML20039D022 (6)

Text

. . UNITED STATES CF Al* ERICA , %5 Q, AUCLEAR hEGULATORY CCMMISSICN fN' '

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g ATCMIC SAFETY AND LICENSING 30ARD -

Before Administrative Jud es6 -JM[

Q[ n u c;" 10 G3I ? CM Louis J. Carter, Cna irman 14 ,J Dr. Cacar H. Paris Q gm @j(f;,,:.a [ / ..

Mr. Trederick.J. Shon y,,g a - , , , c],-

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e-In the Matter of  : Docket Nos:

Consolidated Edison Company of hew Yo rk

• 50-247 c;- 1; 50-280-or (Indian Point Unit 2)

Power Authority of the State of hew York * / x)&Cil

/ ,dh s (Indian Point Unit 3)

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L Llg 01937x lu CONTENTICNS OF fa PARENTS CONCERNED ABCUT INDInN POIKT

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g Pirents Concerned Abcut Indian Point, on behalf of 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 tha psychological trauma of a disaster, and are not adecuately protected by the Radiological Emergency Response Plan.

BASES

1) The radiation doce absorption rate for children is significantly higher than for adults, but ccrrespondingly heightened protective ceasures have not been designed for them.

2) Families residing within the ten-nile hPZ have been given no infornation or irstructionel crochuroa. To be effective, emergency planning infornatien nust be widely dis-seminated, extremely detailed, and available in several languagec.

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3) Tr.ere is no financisl. commitment on the part of local government or the Nuclear Facility Operators to pay for the dissemination of emergency planning 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 to 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 heibht of radiation exposure, to be evacuated by bus.

6) The buses planned to be used to evacuate the transportation dependent population are the same buses which will be used first to evacute schools. Thus, any pre-school 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 IPZ 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 auses, at school reception centers, or at con 6re6 ate care centers to handle the psycho-logical trauma which children will undergol.in a nuclear emergency. Frantic, uncontrolltble cehavior may htmper the entire emergency response effort.

10) Volunt.ary participation or school personnel in an emersency is depended upon and shculd not be. Teachers, administrators, 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 ce difficult to locate when not on duty and thus cannot be counted on to drive buses during an evacuation. .s t the very laust, lo-cating aus drivers will add time to the evacuation procedures.

13) School personnel have no particular radiation disaster training and thus are ill equipped to oecome 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 e.nd privately sponsored

- cultural and athletic pursuits such as music, ballet, scout meetings, and sport practice. Since there are no instructions to parents re6arding 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.

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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 emergency planning zone who take special medication. If they are forced to evacuate without a supply of their medication, serious impeirment to their health could result.

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

20) The Radiological E=ergency Response Flan calls on the resources of communities outside the 10 mile EFZ to help in the evacuation efforts. Local officials may need those resources to implement local emergency plans which are being

_4_ . .

o 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 event 6of 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.

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 emer6ency.

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 net been designed for

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them.

2) There is no plan for attending to the psychological 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 cwn protective measures to insure the safety of their children. These measures may include self-evacuation which, carried out in an ad hoc fachion, 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 nile EPZ have been given no information or instruction as to how to protect their children from the possible ingestion of radiation. To be

_5 effective, emergency planning information reqarding tho 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 dissemination of emergency planning information.

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

The resources of.31ythedale Children's Hospital and the New York School for the Deaf, for example, will be stnained as frantic parents try to make arrangements for their children, and as institutional staff are distracted by their own parental 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.

2) Parents are expected, under many circumstances, to evacuate withot their children. Parents are unlikely to leave the area without their children. Particularly severe problems are likely to ensue when parents who are working outside the 10 711e radius but whose children are within the 10 mile radius at the time of an accident, return to the area in order to evacuate as a fanily unit.

3) Parents will attempt by any means possible to get to their children. They will converge on schools, causing i

traffic congestior., confusion, and a delay in the evacuatinn l 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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Coorg:ncy praccduras cannot ba rolicd 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 dtills and to disseminate emer6ency 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 smergency personnel cannot be expected to perform adequately during a real emergency.

IV. ihe physical and psychological envircament of children will be improved by permanently shutting down the Indian Point Nuclear Power Station.

3ASES 1.) 1he risk of an accident with a potential for offsite releases of radiation, core de6radation, and/or loss of containment integrity will oc si6nificantly reduced by cold shut down of units 2 and 3.

2) Parents, teachere, 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 signifienntly reduced by cold shut down of Units 2 and 3

3) Viorkers in the plant who are parents or potential parents are exposed to unacceptiale level:, of radiation due to operational and manae ement practices at the plant. Chese workers are at risk of disease and genetic will be reduced b.y damace to their offspring. There risks shut down of units 2 and 3.