ML20054J311

Reorganization of Witnesses Necessary to Prove Contentions 3.7 & 4.7 on Emergency Evacuation & Notification.Svc List Encl

ML20054J311
Person / Time
Site:	Indian Point
Issue date:	06/21/1982
From:	PARENTS CONCERNED ABOUT INDIAN POINT
To:
References
ISSUANCES-SP, NUDOCS 8206280473
Download: ML20054J311 (9)

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COI@iISSION beforeth,eATOMICSAFETYANDLICENSIhGBOARb

'62 di 25 R2 Z0 In the Matter of  : (- W

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,G & 5 E Consolidated Edison Company of BAE-New York (Indian Point Unit 2) : Docket Number 50-247SP Power Authority of the State of New York (Indian Point Unit 3) : Docket Number 50-286SP June 21, 1982 PARENTS CONCERNED ABOUT INDIAN POINT REORGANIZATION OF WITNESSES

.TO PROVE CONTENTIONS 3.7 & 4.7 Witnesses necessary to prove contentions for which Parents is the lead intervenor are listed.herein and grouped according to themajor points addressed in their testimonies.

This is not meant to and does not limit the testimony of any witness to the specific point under which he or she is listed.

Numbers in parenthesis refer to'the witness numbers as listed in "Index of Witnesses Presenting Testimony on Behalf of the Intervenors: UCS, NYPIRG, RCSE, WBCA, Parents, WESPAC, F03/

Audubon and on behalf of the Attorney General of the State of New York.

Because we anticipate that many of our witnesses will not be available during the summer months due to vacations and other previous committments, we are unable to eliminate witnesses because we do not know who will be able to testify on any given date.

! B206280473 820621 0}

l PDR ADOCK 05000247 Q PDR

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3.7 THE PROBLEMS OF EVACUATING CH'ILDREN FROM THREATENED AREAS HAVE NOT BEEN ADEQUATELY ADDRESSED IN THE PRESENT EMERGENCY PLANS .

I. Some parents do not have transportation at their dis-posal at all times. Parents who have to evacuate by public transportation will have special problems.

Agata Craig (11) Loretta Brunda i

Jamie Greene (12) Evan Litty(56)ge (55)

II. The reception centers designated to receive our children have not been adequately prepared to meet even basic needs and certainly not energency needs.

Robert Johnson (18) Anthony Napoli (89)

John Moore (51) John Indusi (124)

Vince Rubeo (86)

III. Public officials are not convinced that the evacuation of school children by bus will work.

Richard Wishnie (33) Richard Herbeck (34)

IV. Families and people who care for children with special needs cannot successfully evacuate.

(a) emotionally disturbed children Ronnie Wilkin Schwartz (54)

(b) handicapped Evan Litty (parents 56)*

(c) children with medical conditions Evan Litty (56)*

Susan Scheffel (123) ,

(d) children home alone Gerald T. Kapusinsky (80)

Nancy Sheer (112)

V. People who are directly responsible for carrying out emergency plans and ensuring the safety of children have not been adequately prepared and have expressed doubts about their willingness to, participate.

(a) Day care center operations and babysitters have indicated their concerns about caring for the children of others in a radiolo6 1 cal emergency.

Phyllis Hilbraun (99) Kathy Feit (167)

Sally Zeigler (100) Linda Puglisi (161)

Lillian Moore (130)

(b) Bus drivers have no training, equipment or contracts, and are not familiar with the evacuation routes.

Fern Narod Sheik (105) Sonny Hall (39)

. Tom Turner (107)

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(c) The police do not hav.e adequate equipment, training '

. or personnel;' therefore, lack of confidence that they can communicate effectively and ensure public safety.

Ronald Goldfarb (34) Reginald Iambruschi (37)

(d) Ambulance corps personnel have expressed reservations about their ability to meet the medical needs of the public in a radiological emergency.

Earle Ellefson (85) Edward Connelly (150)

Albert Johnson (108)

(c) Fire fighters are concerned about massive congestion and communication problems.

Stanley Brooker (151)

VI. Special facilities will have extensive problems in attempting evacuation of children.

. (a) Schools have many problems in evacuating children which are not addressed by the plan.

(b) Teachers, whose lives are dedicated to the welfare of children, have pointed out the following inade-quacies in the plan:

(1) Teachers have reliable knowledge about the needs of their students, but have not been consulted by tne planners and their input has not been incorporated into the plan.

Paula Myers (158)

(c) School administrators are uncertain that the plan can be implemented.

David Siegel (81) Toby Gersony (90)

Leon Bock (95) cleland conklin (98)

Richard Dunne (82) Colleen (109)

Murray(110)

John Iurato (87) Lynn Doughty (d) No contractual or economic provisions have been made with bus companies or drivers.

Dick Alexander (83)

(e) Teachers cannot be depended upon to stay with the children.

John Rodin (84) Vincent Rubeo (86)

(f) Children participating in off premises programs during school hours are not covered by the evacuation plan.

Ray Bowles (85) h....

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, (g) Teacher training does not include a response to a

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radiological emer6ency.

John Livin6ston (114) Ruth Isaacs (117)

(h) Teachers do no't have medical supplies for a radio-logical emergency.

. Barbara 'ochman G (115)

(i) Teachers have indicated that children will not respond

. to their instructi'ons to evacuate because parents have given other instructions.

Barbara Hirschman (116)

(j) Some teachers have medical problems which may prevent them fro'm fulfilling the role assigned to them.

Breda Curran (118)

(k) Lack of confidence in the plan will interfere with teacher cooperation.

John Indusi (124)

(1) Children reflect the anxiety of parents who lack confidence in the evacuation plan, and teachers cannot reassure them.

Maggie North (119)

(m) Teachers and students in school districts which border the 10-mile EPZ will have special problems.

Eleanor Kahn (120)

(n) The evacuation plans regarding adolescent children are unrealistic and inadequate.

Mary Lou Gohring (125) David Churchill (127)

(o) The evacuation plans regarding very small children are unrealistic and inadequate.

Phyllis Mendelson (155) Charlyn Appolonio (162)

Abby Perl (156) Margaret Davis (163)

Judith Glass (159)

(p) Health personnel are not equipped with sufficist medical supplies necessary to maintain treatment far children with chronic medical problems.

Elizabeth Sekelsky (88) Clare Rosen (121)

(q) The evacuation plan does not cover all schools and in some cases has given inappropriate instructions to other schools.

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- Eleonarc Bronzo (91) Arlene Tift (92)

Lynn Kauderer. (93)

2) The plan does not provide for evacuation of children in

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camps and parks.

Ronnie Witkin Schwartz (5h)* Judy Kesselman (71)

Linda Co (75)

3) Public after school recreation programs have not been provided for in the evacuation plan.

Kathe Saunders (73) Helen Barnham (79)

Willian Rodriguez (102)

Syd Ginsberg (78)

Stephen Elkins (69) h) Private recreation programs with large student enroll-ments are not - provided for in the evacuation plan.

Vincent Savastano (9h)

Shareane Baff (111)

5) Private recreation prograns that offer individual or small group instruction are not provided for in the evacuation plan.

Joan Fine (7h) Monya Brown (77)

Phyllis Rodriguez (76)

6) Churches have received no instructions for evacuating

• children attending services or classes David Wayne (97) Robert Hare (96)

Michael Robinson (101)

VII A panel of parents will testify on the following problems posed by the p1hn.and its evacuation of children:

a) children home alone Nancy Sheer (112) Kathy Pierpont (lh2)

Elise Lentz (13 6) Ervine Kimmerling (lh5) b) lack of confidence in plan and ability of officials to implement it Mary Bulleit (131) Helga Ancona (135)

Jane Courtney (13h) c) disregard of school evacuation by parents Betsy Doepken (122) Susan M. Teasdale (133) d) anxiety ofchildren Daniela Misch (129) e) children with babysitters .

Madeleine and Marc Holzer (lhl)

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I f) parents with children in different schools Eileen L'cGovern (lkh) Karen Ford (lh0) g) children who live outside the evacuation zone but go to school ,

within the EPZ l Ellen Burgher (138)

VIII .In order for any evacuation plan to work it must be thoroughly explained to all participants and rehearsed, but such preparations will be damaging 3 to the emotional lives and he'althy developnent of children.

Dr. Arthur Zelman (10)

II The plan makes untenable assumptions about the responses of parents outside  !

j the 10-mile EPZ about emergency workers, and abcut children. j Dr. Julie Palmer (153) Dr. Kai T. Erikson (lh8)

Dr. David Elkind (10h) Dr. T. Berry Brazelton (128) j l

I Psychologican and social damage will result if families are separated during an evacuation. r Dr. Albert J. Solnit (15h) Dr. Jerore Kagan (103)

Sheilah Rechtshaffer (132) Sherry Horowite (lh6) d 1

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4.7 The present emergency planning brochures and present means of alerting and informing the population of an emergency do not give adequate attention to problems associated with persons who are deaf, blind, too young to understand the instructions, or who _

do not sp eak English. ,

I. Incomplete notification of the public by brochure and _

siren in case of nuclear emergency will result in failure

. of emergency plan.

a) Not all members of the general public have received the correct brochure or heard the sirens during testing..

Feralyn Woods (5) Fabel Cronk (6) Lynn Gunzenhauser (8) .

Pat Chazen (13) Gertrude -nd Henry Gillette (14)

Joan livingston (114) Mary bulleit (131) -=

b.) No special provisions have been made for notification of gitizens who are disabled by virtue of being, i

1) Deaf E Clifford and Nancy Rowley (58) -

Oscar Cohen (58a) J Barbara Blattstein (59)

2) Elderly Seymour Greenbaum (62) c.) People who' spend a considerable amount of time -

vithin the 10 mile EPZ but live elsewhere would not know what to do in the event of emergency. .

Raymond Bowles (85)

Iois Jessup (126) -

d.) Tne brochure is ambiguous as to how non-public schools should evacuato.

Jane Capon (164)

11. Not all people who have received the emorgency planning brochure understand what they are expected to do -

in the event the plan is implemented. ,

a.) the general population is uncertain of the procedure they are expected to follow. _

Richard Altschuler (3) A=y Kriveloff (4) =

Myra Spiegelran (137) _

b.) The emotionally and develop =entally disabled are incapable of effectively undersknMnv the brochure 3 Charles.Avalt (49) Richard Iand $50)

Pat Bethge (52)~ 'Betsy Bergman (53) "

l l c.) Parents are unable to explain the plan th their l children in a meaningful manner.

Barbara Hickernell (7) Karen Henes (9) Micheal Holland (29)

Daniela Hisch (129) d.) The elderly are unsure of the steps they must take under the plan.

Seymour Greenbaum (62) Susan Simon (65)

Sari Eklund (143) e.) The physically disabled do not understand how they are to follow the brochure 8s directives.

Gladys Burger I63) .

Hattie Coffee (64)

,f.) Public inforcation is not prepared in any language other than English. The non Ihglish speaking.

population vill'be confused by and ill prepared for a radiological emergency.

Michael Holland (29) 111. The content of the brochure is incomplete and misleading. ' '

Kathleen Toscani (139)

Theodora Dyer (147)

O pe i.. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _

'Lbuts d. Carter, Esq.. Chairman RMTtf UOfd0. Usq.

SiRVICE LIST Steve LS1ps12. Esq.

, A:)ministrative Judge Atomic Safety and Licensing Board Eavironmental Protect 11n Burea

,U.S. Nuclear Regulatory Comission HonIrable GilbIrto Cerana-Valentin hw mk State Attcrney Member cf th: Council cf th2 n 8*

Washingtin, D. C. 20555 City cf New York Two or Tr ent*.r 4 New York, H.Y.

'Dr. Oscar N. Paris

. District f11 f> 10047 City Hall w Y rk, New York 10007 &C $N ' Alfred B. Del Bello A . a a censing Board j'd .S Westchester County Esecutive U.S. Nuclear Regulatory Cornission Washington. D. C. 20555 Honorable Arthur J. Katzman S C "" U Hember of the Council of the "

• Mr. Frederick J. Shon City of New York m l N J;..n qL - - '"(601 Administrative Judge District e22 City Hall *T

,C) og t Atomic Safety and Licensing Board New. York, New York 10007 cv M Andrew S. Roffe. Esq )

U New York State Assec51 U.S. Nuclear Regulatory Comission Washington, D. C. 20555 Jonathan L. Levine. Esq.

g> g4. .- c - ;; Albany. N.Y. 12248 Rockland Citizens for g a h t"- @tRenee Schwartz Esq.

Brent L. Brandenburg. Esq. Safe Energy . 8 j g[ Botein. Hafs. Sklar & Herzberg Assistant General Counsel P.O. Box 74 oM s Attorneys for Metropolitan Consolidat'ed Edison Co. New City NY 10956 54 M :w

• Transportation Authority of Hew York. Inc.

4 Irving Place Marc L. Parris Esq. M%$h o 4 200 Park Avenue hew York. N.Y. 10166 New York, N.Y. 10003 County Attorney County of Rockland .$

a s.$ eqagMg Stanley B. Klimberg 11 New Hempstead Road General Counsel Paul F. Colarulli. Esq. New City. NY 10956 g g y to New York State Energy Office Joseph J. Levin, Jr. Esq.  % O 23 h 2 Rockefeller State Plaza Pamela 5. Horowitz. Esq. Geoffrey Cobb Ryan Albany, New York 12223 Charles Morgan, Jr. Esq. Conservation Comittee Morgan Associated. Chartered Chairman, Director 1899 L Street. N.W. New York City Audabon Society Washington, D. C. 20035 71 West 23rd Street, Suite 1828 ,

hew York, NY 10010 Charles 11. Pratt. Esq. Honorable Ruth flessinger Thorus R. Frey. Esq. Greater New York Council 11 ember of the Counct) of the Power Authority of the on Energy City of New York State of New York c/o Dean R. Corren, Director District #4 10 Columbus Circle fiew York University City Hall New York. N.Y. 1001g 26 Stuyvesant Street New York, New York 10007 New York, NY 10003 Ellyn R. Weis. Esq. Honorable fliriam Friedlander William S. Jordan. III. Esq.

• Atomic Safety and Licensing Member of the Council of the Harmon & Weiss Board Pene) City of New York 1725 I street. N.W. , Suite 506 U.S. Nuclear Regulatory Comission District #2 Washington, D. C. 20006 Washington. D. C. 20555- ' City Hall New York, New York 10007 Joan Holt. Project Director ' Atomic Safety and Licensin9 1ndian. Point Project Appeal Board Panel Honorable Carol Greitzer New York Public Interest Member of the Council of the U.S. Nuclear Regulatory Comission Research Group Washington, D. C. 20555 City of New York fr-Gee +=en-Street YgM/g* .

District f3 New York, N.Y. 10007 Honorable Richard L. Brodsky City Hall Member of the County Legislature New York, New York 10007 Charles A. Scheiner, Co-Chairperson Westchester County Westchester People's Action County Office Buildin9 Honorable Stanley E. Michels Coalition. Inc. White Plains. NY 10601 Member of the Council of the P. O. Box 488 City of New York White Plains, N.Y. 10602 District 96 City Hall

- n -- - - - - - New York. New York 10007 44 Sunset Drive Croton-on-Hudson, N.Y. 10520 Honorable Susan Alter John Gilroy. Westchester Coordinator Member of the Cosncil of the Indian Point Project City of New York Lorna Salzman . New York Public interest Mid-Atlantic Representative Research Group District e32 Friinds of the Earth, Inc. City Hall 240 Central Avenue New York, New York 10007

,208 West 13th Street White Plains, New York 10606 New York, N.Y. 10011 Honorable Edward C. Wallace 2tpporah 5. Fleisher Jeffrey M. Blum, Esq. Member of the Council of the W;st Branch Conservation New York University Law School City of New York Association 423 Vancerbuilt Hall Councilmember-at-Large, Manhattan 40 Washington Square South City Hall 443 Buena Vista Road New York, N.Y. 10012 New City N.Y. 10956 New York. New York 10007

• 0ocketing and Service Section Charles J.'Malkish, Esq. Honorable Mary Pinkett Litigation Division Member of the Council of the Of fice of the Secretary The Port Authority of City of New York U.S. Nuclear Regulatory Comission New York and New Jersey Washington, D. C. 20555 District #28 One World Trade Center City Hall New York. N.Y. 10048 . New York, New York 10007 Mayor George V. Begany Village of Buchanan 236 Tate Avenue Honorable Mary T. Codd Buchar.an, N.Y. 10511 David H. Pikus, Esq. Member of the Council of the City of New York Richard F. C2aja. Esq. Coune.11mecter-at-Large, Staten Island Judith kessler, Coordinator 330 nadison Avenue -

City Hall Rockland Citizens for Safe Energy *:ra Y M . NY

• 0M 7 300 New Hempstead Road New York, hew York 10007 N W City, N.Y. 10956 ' .