ML20039E149

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Affidavit of D Valinsky That Nypirg Survey Was Not Designed to Elicit Objective Responses Re Attitudes or Knowledge of Emergency Evacuation Plans But Was Designed to Intimidate & Frighten.Prof Qualifications Encl
ML20039E149
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/17/1981
From: Valinsky D
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
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ML20039E141 List:
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NUDOCS 8201060583
Download: ML20039E149 (19)
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Text

% . Exhibit A d.,

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AFFIDAVIT OF DR. DAVID VALINSKY g bl/L , ,, s David Valinsky being duly sworn hereby deposes and says

1. I reside in Scarsdale, New York.
2. I have a B.S.E. in sociology and economics from 1

Temple University; an M.B.A. in statistics from the City College of New York; and a Ph.D. in statistics and business from Columbia University.

3. I have served as member of the faculty at the Bernard M. Baruch College of the City of New York since 1940, and have held the post of Chairman of the Department of Statistics and Computer Information Systems since 1971.

For the past three decades, I have studied and used scien-tific survey sampling principles, not only as a teacher, but also as a statistical and survey consultant in marketing and advertising research, pharmaceutical research, industrial marketing, public polling and social research, health care delivery, federal trademark problems, agriculture, and quality control. I have designed survey samples and questionnaires. I have acted as a research consultant to numerous public and private corporations and to various state and federal agencies, including: the City of New York; Fuller, Smith and Ross; L. Harris and Associates; the s

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  • election unit of the American Broadcasting Company; Coca-Cola International; Yankelovich, Inc.; Interpublic; a..d Benton and Bowles.
4. I have been elected a fellow in the Royal Statistical Society of Great Britain, the American Association for the Advancement of Science, and the American Society for~ Quality Control. I have written three books and.

numerous. articles and have presented numerous papers on the theory and application of statistical and survey tech-niques. See Exhibit A.

5. I have read and examined the document entitled

" Parents' Survey," dated October 27, 1981, which was sponsored by New York Public Interest Research Group, Inc.

(NYPIRG). See Exhibit B.

6. I have made no attempt in this affidavit to assess the validity of whatever scientific sampling process, if any, was employed NYPIRG in the distribution of the survey-ing instrument.
7. The main purpose of a scientific survey instrument is to elicit data and objective responses that are suggestive of attitudes or behavioral patterns. An atmosphere which facilitates an ease of response should be created. The order and sequencing of topics to be covered and the listing of questions should be set up to facilitate I

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the: flow of ideas from topic.to topic. Initial questions should be employed'to establish the proper objective attitude for the respondent. Open-ended. questions can be important in. order to permit the respondent to provide the full range of information at his disposal.

8. It is my opinion that the survey instrument - was ' not intended to elicit objective responses regarding attitudes or knowledge pertaining to the respondents' emergency evacuation plans, but rather that the instrument was intended to intimidate, f righ ten, and create a sense of' helplessness-in those who read it. nie manner in whict

" questions" are stated and- arrayed is; also designed to create bias, direct' responses, and _ ultimately to be a. call' to action on the part of the reader. The NYPIRG survey.

E instrument fails utterly to meet any ofLthe well-established rules governing survey questionnaires.

9. NYPIRG's apparent purposeJin taking the survey--to focus - upon the separation of. psrents and children --in the event of a nuclear emergency--immediately creates anxiety and begins the process of biasing the balance of the responses.
10. The very title of the instrument- " Parents' Survey"--followed immediately by questions about children, establishes certain defenses and attitudes on the part of l

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the respondent which hopelessly bias the balance of the responses.

11. When the foregoing is considered with the third j question and its subparts in which reference to "a nuclear emergency" is made,_ intimidation and fear result. This result will affect subsequent questions and raise sufficient fear and bias to taint the validity of responses to those questions.
12. The constant theme of subsequent questionsLis family, and especially child, separation. This theme effectively reinforces and exacerbates the sense of fear, anxiety, and helplessness already prompted by the instrument. For example, question number 8 seeks only to build upon the anxiety and fear already created. It can have no other purpose. If one were really concerned about ~

patterns of family location, one would seek to establish a matrix of location for each f amily member. It is useless to-know the number of locations for purposes of emergency planning.

13. The " survey" is neither designed nor constituted to be a genuine instrument for data collection, i.e., one capable of obtaining objective, precise, usuable information. It is disorganized, moving from the topics of parents to children to separation to " family . . . nuclear emergency plans" to school

information efforts and back to separation again.

14. As structured and in the format ' employed, not a single question ' exists which woulc be considered acceptable as standard professional survey practice.

m &

David Valinsky, Ph.D.

[/Wff y'NR'k' cci w /s y N A - Y' 4 Subscribed and-sworn to before me this /) # day of December, 1981.

IRVING POTASKY Notar) Perme. State of New Ycrk No. 413141705 ouat!!in en Queens County Commiss:on Erottes f4 arch 30,1963

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Notary Pu p c ' -

'., VITA Exhibit A .

NAME David Valinsky 000KEUCP A RTM ENT Statistics __,

u m..C BANK Chairman-Professor Eg p tg' I11g pj j d PART TIME ,,

1. EDUCATION O, F_ R. C.E. .' ? E. ' ' E '

Degree Institution Date B.S.E. Sociology,_ Economics T e m p le University 1936 M.B.A. Statistics The City College of N . Y '. 1943 Ph.D. Stati.atics Columbia University 1962

2. FULL TIME AND PART TIME ACADEMIC AND OTHER EXPERIENCE A. Teaching Experience City College of New York and Fellow to Professor 1940 to Bernard M. Baruch College, CUNY Department of Business present Administration and Statistics -

Baruch College, CUNY Chairman, Dept. of 1970 to Statistics Present Rutgers University Adjunct Assistant 1952-1953 NYU and Syracuse Joint Appointment 1957 as Adjunct Lecturer B. Consulting and Research Activities

-Since 1946, Dr. Valinsky has acted as a statistical consultant in the Iollowing seeturs: s

1. (;overnment. Public Affairs and Civil Rights Developed "Jmpartial" Quantitative Reapportionment Plan for the State of Alabama. (Implementation ordered by Federal District Court, January 3, 1972.

Upheld by Supreme Court 1973 Reapportionment Plan for the State of Mississippi,

  • 1975. Implecentat. ion of nnfified version of plan e r.le t eil by ll . S . Supreme Court. 1978.

Restructured Alabama Jury System -- Jury selection procedures and composition determined through probability sampliny. (Upheld and implementation ordered by $th Federal Circuit Court of Appeals -

July 2, 1971.)

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B. Consulting and Research Activities -

continued Expert Nitness for,American Civil Liberties Union since May 1969 - 1974 Lawyers for Civil Rights under law -

1973-1974 Cuardian Association - Organization of Black lawyers dealing with discrimination in oolice_ hiring and-promotion. 1973 .

Mayor's Committee on Management Surveylof the City of New York on (Fire Logistics)_ 1951-1952 Expert Witness, Civil Aeronautics Board, Southern Transcontinental Air Case 1959 Expert Witness,Coca' Cola Corporation Trademark Federal Litigation 1978-1979 Expert Witness, C. Morgan Ltd. - Sears Roebuck Corp --

Equal Opportunity Litigation 1979-1980 Expert Witness, FTC (Formica Trademark Litigation-1980 Expert Witness, (Bo ehrin ge r I n g e l h e im Ltd. vs. Primo Pharmaceutical (U.S. District Court, New York-1979-l980

~~'

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(Generic Prescription Drug's)

Expert Witness, Federal Trade Commission, Columbia Records 1963.

Mayor's New York Temporary Commission on New York City Finances 1965.

Office of Mayor of New York -- Office of Aging 1971-1973 Department of Corrections -- State of New York 1970.

Expert Witness - Justice Department - ASCAP 1958-1959.

Expert Witness - HEW vs. North Carolina University System Desegregation Litigation - Representing 19 States in the Adam's vs. Richardson case. States 1979-1980.

2. Medical and Hospital Administration r Statistical Consultant to Health Insurance Plan - 1951.

i Principal Investigator, Mt. Sinai Hospital, " Optimum ,

l Utilization of Hospital Ancillary Services " funded by i N.I.H. H.E.W. -- 1965-1979.

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' 2* . Medical and Hospita1' Administration - continued The following 8 monographs comprise the Final Report to HEW USPHS, Health Service Research Center, with Dr. M. Rabinowitz and Barry Dumas, 1979.

" Optimum U tilization of Hospital Oncillary Services", 211 pages.

"I Simulator-Based Planning Model for Hospital Microscopy Laboratories", 204 pages.

" Hospital Blood Banking - An Evaluation of Inventory Control Policies", 1972, 325 pages.

" Simulation-Based Scheduling Model for Radiology", 1979, .", 9 pages.

" Total Hospital Systea/A Simulation", 1979, '3 pages.

" Hospital Adminissions System", 1979, 106 pages.

" Surgery Scheduling Systems", 1979, S6 pages.

" Determination'of Transfers for MISPLACED Patients: An Analytical Op timiza tien* Prece d u r e , 1979_, 32 pages.

Maimonides Hospit'al -- OR consulEant to D'irector of Hospital.

Presbyterian Hospital (Columbia University), School of Public Health, 1970-1971.

Evaluation of Hospital'Research Programs for N.I.H. -- 1969 to 1974. (Study Sections)

Consultant to Mt.Sinai Hospital - Operations Research 1965-1979.

3. Business Consulting - Developed more than 45 National and Regional Probability Samples (Partial List) 1964-1966 American Broadcasting Co.(Election Unit) 1964-1968 L. Harris and As socia t e s(Political' Polling) 1966-1978 John F. Kraft (Political Polling) 1965-1968 Interpublic 1958 J. Walter Thompson .

1952-1956 Puller, Smith and Ross 1956-1959 Liebman Breweries 1956-1958 Medimetrics Institute

  • 1958 Ford Motor Company 1962-1963 Walter Kidde Construction Company -

1970-1972 Coca -Cola International 1954 Acme Steel Corporation 1956 Ely Lilly Pharmaceutical Company 1965-1976 Market Facts Inc.(New York)

L962-1966 Standard Rate and Data Corporation 1965-1979 Benton and Bowles

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3. Business Consulting _- continued

' 1972 Oxtoby-Smith 1969 Charles Pfizer Inc.

1950 Cus tomer - Audit Bureau 1967-1973 Motivational Programmers 1974 Cencral Foods Corporation 19h7-1968 Kenyon Eckhardt 1967 Young & Rubican 1964-1969 Yankelovitch Inc.

1967- Columbia Records 1962-1967 Becker Research

  • 1958-1960 Joel Dean Research 1979-1980 R. Sorenson & Assocs.

19 6 5 -l' r e s e n t R.- Bruskin Assocs.

1972-1980 Monroe Mendelsohn Research 1979-1980 Feldman Research 1980 RX OTC Research Reports

4. 1943-62, U.S. Army Experience, Private to Captain- .

a) Chief Statistician Control Branch, Army Services j Training Center, Aberdeen Proving Ground.

. i organi:ed and administered statistical control l ranch, b) blministration and Finance Officer Administration; o f ficer in charge of mechanical opera tions , Of fi ce- of the nependency Bene fi t s ; coordina ted and conduc ted 't raini ng program for 350 clerks; pinnned and directed the installation of mechanical operations systems on Class.E, St. Louis, Missourf c) Gene ral Sta f f Of ficer, Pentagon. (Reserve 1947-63)

3. ACADliMIC ANii PROFESSIONAL !!0NORS U. S. Army Commendation Medal (1946)

Elected Fellow in Operations Research Sochry of America (1955)

Elected Fellow in Royal Statistical Society of Great Britain (1957)

Elected Fellow in American Association for the Advancement of-Science (1959) -

Elected Fellow in the American Society for Quality Control (1964)

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-Elected Beta Gamma Sigma Honorary Society - Faculty Representative (1973) l L

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  • RESEARCil GRANTS USPilS'., National Institutes of Health and Health Services Research Center Grants " Optimum Utilization of Hospital Ancillary Services" -

Research conducted at Mt. Sinai Hospital as Principal Investigator -

-Supervisor of 8 professional researchers.-

1964-6 'Ist Grant- ,-

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1967-9 2nd Grant 1969-70 3rd Grant 19 71~- 7 2 4th Grant-1973-74 5th Grant

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1975-78 6th Grant-

5. OTHER SCliOLARSilIP AND ACADEMIC OR PUBLIC SERVICE Summer Session Supervisor Dept. of. Business Administration (1947-195~

Taught Mathematics in.the Army Specialization Training Program -

City College (1943)

Instituted.and developed Cooperatiye Work-Study Training Programs -

(_400 students).Dtyartment of Business Administration. Served as Coo'rd ina tor o f 10 programs . (1947-1965)

Chicami e, lia r va rd - lin i ve rs i r y Ford Foundation 1965 Faculty Seminar Chicago I:n i ve rs i t y Ford Foundation -1966 Faculty Seminar Saxe award fo r con t ribu tion:! to faculty - student ac t i v i t ics . (19 5 6)

Organi cd the fi rs t student chapter'- ASQC s

Supervisor, Gradua te Ope ra tions Research Specializa tion Developed the following undergraduate specializations:

Sta ti s t ical Theo ry , Psyt-home tric s , Soci ome t ri cs , Ope ra ti ons -

Research and Systems, Computer Methodology, Quantitative Analysis in Marketing, BBA-MBA-4 yr. Accelerated Program in Statistics,0R and Computers Developed the following graduato specialization programs: .

MS in Statistics, Operations Research; Computer Methodology Ph.D. Program - Quan tit a tive Analysi s ,MBA program in Operations Research Wrote and introduced over 50 undergraduate and graduate courses in Statistics and Operations Research and Decision Theory.

President, Dessoff Choirs (1971-1972), Treasurer, St. Cecilia chor'us 9

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6. - SERVICE TO . COLLEGE AND UNIVERSITY .(PARTIAL LIST)
a. University-Ch~ airman, University Faculty Senate (UFS),.1974-78

-Executive Committee, UFS -11968.- present . .

Board of-Higher Education, Ex-Officio Member 1976-78 (Executive. Committee, Committee on Long' Range Planning, '

Administrative, Affairs Comm. Fiscal Affairs.(1974-76)

Board of Directors CUNY- Research Foundation 1979-date Chance 11or's' Task Force for tho' Future of CUNY

-BHE Commission on Governance University' Advisory Committee or Health. Services University Committee for Imple.7entation of: Open. Admission-Several University Search Committees CUNY-SUNY Master Plan Committes Preparation and Presentation - oral and written testimony.

(20 legislative and governmental agency committees and. hearings)-

University _ Committee on Academic' Computer Usage -

b. College and' Department of Statistic Chairman Department of Statistics - 1971-present Executive Committee of Departm'ent - 1950 present .

School of Business,-P16 B committee 1971_present Graduate Studies Committee Chairman 1972 present:

Member of Baruch College Transition Committee.

Presidents Advisory ~ Committee,-1974-1977 Presidents' Committee.on Baruch College Governance Baruch College Registration Advisory-Committee President's Committee'on Honorary. Degrees Baruch' Representative to Graduate Faculty Council Chairman, Ph.D. Curriculum Committee 1969 Chairman, Ph.D. Examination Committee-1967-8, 1973-4 Committee on Distinguished Scholarly and Excellence in Teaching 1980 Committee on Public' Policy Center 1979 Board of Directors Center for the Visually Impaired.197.9-80

7. MEMBERSHIP AND ACTIVITY IN LEARNED SOCIETIES Fellow, Operations Research Society of America (1955). converted to

" Member." Treasurer, Health Division, 1974-1976; Chairman, Program Committee, National Conference, New York, May 1978.

Fellow, Royal Statistical Society, Great Britain American Society for Quality Control (Chairman, Metropolitan Chapter and Fellow, Program and arrangements Chairman, National-Conference) .

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7. MEMBERSHIP AND ACTIVITY IN? LEARNED SOCIETIES - continued-j JFellow, American Association for Advancement of Science American Marketing-Association

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American Statistical Society Intl. Assn. of Survey Statisticians,: Intl.1 Statistical Inst.

8. PUBLICATIONS
a. Books:

" Encyclopedia of Management, Reinhold Publishing Company, Editorial Advisor on " Statistical'and Quantitative Methods,"

entry on " Statistics," 1963, 60 pages..(Revised 19 71 and 1980)

" Hospital Blood Banking - An Evaluation of Inventory Control Policies," with Dr. Manus Rabinowitz, National Institutes of Health, 1971, 325 pages.

"A Statistical Determination of the Distribution and Number of Ladder and Engine Companies in the City of New York,"

published by the City of New York, 1952,.110 pages.

" Health Operations Research: '"A Critical Analysis Simulation:

State of the Art" 103 pages, Johns-Hopkins Press 1975.

" Concise Guide to Management Decis' ion Making" - Part Two: II ' '

Statistics as a Tool of Decision Making, Van Nostrand Reinhold Co., New York, 1980. .

Articles in Scholarly Journai's:

b.

" Application of Simulator-Basad Planning Models in Hos,pital Laboratories" with Dr. Manus Rabinowitz and Barry Dumas -

Proceedings - ORSA- Health Aeolication Division Proceedings, (1971)

~"A Two-Stage Optimization Model for Inpatient Transfers" with Rabinowitz, M. and Dumas, M.B. - Operations Research, October 1976.

" Compounded and' Composite Probability Distributions in -

Simulation with Dr. H. Stein, Dr. M. Rabinowitz and'B. Dumas, Proceedings A.S.Q.C. Conference, Rutgers University, 1971.

" Simulating Hospital Laboratories: Clinical Microscopy Laboratory-System" with M.B. Dumas, Proceedings of Association for Computing Machinerv, October ~1972 - also published in SIGSIM, . February 1973.

" Simulation of Hospital Blood Banking" -

with Dr. M. Rabinowitz Proceedings of ACM - October _1972. (Refereed publication)

" Clinical Microscopy-Laboratory Planning", with M.B. Dumas, ,

Hospital Administration, December 1974. I p.:._ .

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8. b. Articles'in Scholarly Journals continued

" Determination of the-Optimum Location of Fire Fighting Units in New York City" Operations Research, November 1956.

" Administrative Application of. Quality Control," in' Proceedings of' Columbia _ University Conference of the American Society for Quality Control, September 1957.

" Comments on Determination and Selection ot Data in Operations Research" and Training in' Operations Research," in Transactions of the First International Conference'of Operations Research of America and Great Britian, December 1957.

" Statistical Control Applications to Chemical Experimentation,"-

in Transactions of the Stevens Institute Con ference of .the American-Society f or- Quality Control, January 1958.

c) Professional Pacers (1) Papers presented at Professional Societies American Statistical Association American Management Association Society for the Advancement of Management _

A:nerican Society for Quality Control Operations Research Society First and Third International Conferences on'Cperations Research ,

New York State Society-of~ Certified Public Acco6ntants Association for Computing Machinery The Institute of Management Sciences (2) Papers Presented

" Marketing Techniques Applied to Industrial Research", -

Netherlands Study Group-under auspices of Mutual Security Agency, January 1953 i . " Theory of Games and Statistical. Decision Making", Society for Advancement of Management, March.1953 '

" Optimum Operating Conditions for the Control of the Boll Weevil, Entomological Society of America, Dec. 27,1956.

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8. c) Professional Papers - continued

" Correlation Methods in Marketing", American Management E Association, .tarch 1953

" Determination of Municipal Government Facilities Through Statistical Quality Control", American Society for Quality Control, Princeton University, December 1954 "A' Determination of the Optimum Location'of the Fire Fighting Units i,n New York City", Third Annual Meeting lof Operations =Research Society, held at Columbia University, June 1955 .

" Training of Teachers in Quality Control", presented to

~

European representative Prufessors, Statisticians and businessmen under the auspices of International Cooperation Administration, U.S. Department of Commerce,. June,1956

" Commercial Uses of Probability Sampling", American Society for Quality Control, nutgers-University, September 1956-Moderator of discussion.on " Basic Principles.of Quality Control", the American Society for Quality Control,. held at Rutgers University September 1957 .

U.S. Delegate, Referee and Discussant at First International ~

Conference on Cperations Research, Oxford University, Englane September 1957-Chairman of Panel at Conference on " Statistical Control in Auditing", by the New York-State Soci'ety of Certified Public Accountants and the American Society for Quality Control, at Columbia University, October 1957 Chairman and Discussant at Conference on " Motivation Researn sponsored by the American Marketing Association and the American Society for Quality Control at Princeton University December 1957 Chairman and Discussant at United Nations, on International Applications of Quality Control, March 1958 American Society for Quality Control, " Games and Business .._ ,

Decisions", at the A.S.q.C., May 12, 1959 Annual Joint Conference of American Statistical Association and Society for Quality Control on " Game Theory and Decisions", at Princeton University, December 5, 1959 American Society for Quality Control, on " Linear Programming

- A.S.O.C., May 1960 .

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S. c). Professional Papers - continued American Statistical Association, on " Role ofeStatistician in Business"., National Cash Register Company, :tay 19 62

' Chairman and Principal Lecturer ct'three day. seminar, Americ.

Management Association, " Quantitative Aspects of . Marketing Management",~1962

" Queuing Theory in IIo spitai Administration", American Management Association, 1963.

~ U.S. Delegate and Discussant at Third International Con-ference on Operations Research, University of Oslo, Norway.

July 1963'

" Operations Research in Hospital Administration", University-of Chicago and Billings-General Hospital, July 1964 -

Chairman of seminar, " Project 60", U.S. Department of~Defens Inspection-Specifications to contractors,- A.S.Q.C., May, 196, Series of 9 papers'.at American Management Association,'1965--

69 '

National Health Symposium, . " Admission-Surgery Simulation Models ,' and"Models for Emergency Hospital Care," Carmel, California 1977.

" Decision Models Under Uncertainty" Mohawk Valley Community College, " Engineering Decision .

Models" ORSA Symposium on Health, " Role of the Consumer", May 1969',

Wash. D.C.

ASQC, " Operations ~Research Models for Production Management",

New York, New York, 1968

" Commercial Uses of Probability Sampling", in Transactions of the Rutgers University Quality. Control Conference of the American Society for Quality Control, September 1956.

" Simulation: Health Care state of the Art and Pote'ntial for the future"~- Joint ORSA - TIMS~ National Conference, .

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November 9, 1972 Atlantic City, :lew Jersey.

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3. c) Professional Papers - continued "A Critical Analysis of Simulation in Health Care" TIMS -

Metropolitan Chapter, .'pril 20, 1973

" Simulation - A tool for Health Care Productivity",

Symposium on Productivity in the Health Professions, Universi of Pittsburgh, October 3-4, 1973

" Comparison of Hospital Laboratory Simulation Techniques",

ORSA conference, Dallas, Texas, April, 1972.

Chairman and principal speaker in symposium on " Simulating Hospital Laboratories".ACM urban conference, October 1972.

" Compounded and Composite Probability Dis $ributions in Simulation" with H. Stein, 't. aabinowitz and B. Dumas, American Society'for Quality Control, September 1971.

d) Monocraphs and Professional Research Reports, Doctoral Thesis: "The Determination of Optimum Operating Conditions for the Control of Boll Weevil Infestations,"

Columbia University, 1962, 321 pages.

"The Relative Effectiveness of Chlorinated Hydrocarbon Insecticides in the Control of the Cotton Boll Weevil,"

research report to Hercules-Powder Co., 3 volumes, 1956, 370 pages. .. _ _ _ _ _ . _ . . . .

" Usage of Gas Applicances and Attitudes of Gas Consumers,"

prepared for the American Gas Association, 10 market areas were covered and 10 reports were prepared, composed of 163 pages each.

1954.

"The Dusiness Outlook and Appliance Sales Objectives", for 20 leading U.S. cities, a separate 42 page report was prepared.

This report was prepared for Westinghouse, 1952.

Preparation and Design of more than 45 National and Regional Probability samples. ,

i e) Book Reviews .

" linear Programming - The Sieplex Algorithm, Journal of American Statistical Association, March 1958. ,

" Laplace Trans forms", Electronics Journal,1964

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Exhibit B

  • V NYPIRG hi NEW york publIC IVrEREST RESEARC[I CgROUp,INCe F 5 Beektnan Street
  • New York. N.Y. 10038 * (212 349 6460 cm a., ime -r. w % - - - , o- Q))fyIL-. w.

October 27, 1981 PARENTS' SURVEY '82 JAl{ -4 All :15

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1. How many children do you have (who live with yoqgdh(u.. :: :$q tgs dit and are still in school or are pre-schoolers)? ER,1uCH children

_____ ____ _________________ _________c

2. How many children who stay home during the school day? 2. child ren

__________________ ___ _ ___ ____________c

3. How many children in day care during the school day? 3. children 3a. How many in day care within ten miles dog of the Indian Point nuclear power plants? 3a. children kne 3b. Would your child (ren) be sent home from day care if a nuclear emergency happened don't during school? 3b. yes no know

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3c. Would your child (ren) be bussed by the day e :re if a nuclear emergency happened during school (to another location farther don't from Indian Point)? 3c. yes no know

_._.._ --_________ _ .-_____________ _ c

4. How many children do you have in grades 1-12? 4. children i

l 4a. How many children who attend a school do within ten miles of Indian Point? 4a. children kn 4b. Would your child (ren) be sent home from school if a nuclear emergency happened don't during school? 4b. yes no knov l

4c. Would your child (ren) be bussed by the l school if a nuclear emergency happened i during school (to another location farther n't j from Indian Point)? 4c.,,_ yes no '

l _ _ _ _ _ . - -

! c don't

5. Is your home within ten miles of Indian Point? 5. yes no know i

l

( CONTINUED ON THE BACK )

The New York Pubhc interest Research Group. tre (NYPIRG) is a not-for profit nonpartisan research and advocacy organizaron estabhshed l

l directed and supported by New York State conege and university students. NYPIRG's statt of lawyers, researcners. scentists and organizers works with stucents and cr.or rMens, develop ng eftszenship skdis and shaang pubiac pc..q. Consurnet protectori, higher education. energy. f. scal j eIspon56hty. %)htical soform and socaa! Justice tre NYP!AG~s principal areas of concem -

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  • Is your h m b2twren _ ten to twenty miles from Indirn Point? don' 7-A-------- -
6. yes no kno.

7.

Is an adult at home generally during the school da don'

.------------~y? . . _ .

7.

yes no know 8.

During a normal weekday, in how cany different locations are members of your family --include school, offices, any other regular activity place. 8. location:

9. Does your family have a nuclear emergency plan? 9. yes no 10.

Has your family ever discussed what to do in the event of a nuclear emer gency a t Indian Point ?

10. yes no 11.

Has your child (ren)'s school ever sent home information don't on school emergency plans or conducted a drill? 11. yes no know 12.

Hasthis? your parent-teacher association ever discussed don' t;

12. yes no know .

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13.

Have what you ever received any official information on IndiantoPoint?

do in the event of an accident at ,

don't !:

13. _ yes

. no know g 14 Would your children know what at to do if an accident Indian Point happened while they were away from home and no_t_ at school (after school, weekends)? don't

14. yes no know l

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15.  ;

Would you know what to do if an accident happened at Indian Point while your family was separated? don't i

15. fas no know 6

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Exhibit B a)

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DOCl;ETING & SERV.i. Cv N

Roger 9$Y. avis, being duly sworn, hereby deposes.and'says:

1. I recide at 223-17 56th Road, Bayside, New York 11364.
2. I am a law student at George Washington University and a part-time law clerk at Morgan Associates, Chartered.
3. On December 24, 1981, I visited the of fice of the New York Public Interest Research Group, Inc. (NYPIRG), located at 5 Beekman Street, New York, New York 10038.
4. In the reception area of NYPIRG's office, publica-tions are available for distribution to the public. From this display, I obtained a copy of the pamphlet entitled "In Case of a Nuclear Accident . . . Do You Know What To Do?", printed by the Fund for Secure Energy, Inc.

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RogeyStavis Subscribed and sworn to before me this /I day of December, 1981.

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Notary P

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