ML022630462

Alert, Inc., Petition Filed by TMI-Alert to Improve Emergency Planning to Include All Nursery Schools & Daycare Centers in the Federally Required Radiological Emergency Readiness Plans

ML022630462
Person / Time
Site:	Three Mile Island
Issue date:	09/04/2002
From:	Christian L Three Mile Island Alert
To:	NRC/SECY
References
Download: ML022630462 (21)

Text

TMIA : THREE MILE ISLAND ALERT, INC.

315 Peffer St., Harrisburg, Penna. 17102 (717) 233-7897 FOR IMMEDIATE RELEASE Contact Persons:

Larry Christian Eric Epstein (717)-245-2662 (717)-541-1101 PETITION FILED BY TMI-ALERT to IMPROVE EMERGENCY PLANNING Group Seeks to Include Day-CareCenters and Nursery Schools Harrisburg. Pa, -- September 5, 2002 -- Three Mile Island Alert will file a formal Petition for Rulemaking today with the Nuclear Regulatory Commission to include day-care centers and nursery schools in emergency evacuation planning. The proposed rule would affect all 103 operating nuclear plants in the United States.

Lawrence Christian, the Petition's author, stated,"Since 198o, emergency preparedness plans were supposed to adequately protect the public health and safety by providing reasonable assurance that appropriate measures would be taken off site in the event of a radiological emergency." But Christian noted, "Yet day-care centers and nursery schools have been left out of these requirements for 22 years!" X06[

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TMIA Chairman, Eric Epstein said, "Federal regulations are needed to address existing gaps and provide a reasonable measure of care and planning for out most vulnerable populations." Epstein added, "Frankly, I can't imagine any sane person, company or governmental body opposing this common sense remedy."

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SUBJECT:

SUBMITTAL OF PETITIONFOR RULEMAKING- TO INCLUDEALL NURSER YSCHOOLSAND DA YCARE CENTERS IN THE FEDEARLLY REQUIRED RADIOLOGICAL EMERGENCYREADINESS PLANS Date: 9/4/02 Secretary Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C., 20555-0001.

Dear Secretary:

This petition for rulemaking seeks new Nuclear Regulatory Commission requirements to insure all daycare centers and nursery schools are properly protected in the event of a radiological emergency.

According to my communications with state and county emergency management officials, there are currently no mandated emergency evacuation requirements for daycare centers and nursery schools.

"'Ouroffice has been in contact with the Departmentof Pubhc Welfare. 7his agency either hcenses or regulatesdaycare centers within the Commonwealth.

In conversation with the DPW, the question was asked if daycare centers were requiredto have comprehensive plansfor all emergencies alongwith evacuation proceduresand the answer was no, they did not. The centers were to have a procedurein case offire only. The only way that the DPW could mandate daycare centers to have plans would be through legislation,which is not in place at this time."

- Kay Carman, York County DirectorofEmergency Management Without new NRC requirements designed to insure all daycare centers and nursery schools are properly planned for, preschool children will continue to be left without any: designated relocation centers, designated transportation, approved-child-safety seats, rosters of emergency bus drivers, educational materials, state of readiness checks, inclusion in radiological emergency preparedness exercises, etc.

These deficiencies all serve to pose dangerous risks to all preschool children's safety.

Sincerely, Lawrence T. Christian 133 Pleasant View Terrace New Cumberland, PA 17070 1-717-770-0852

PETITION GUIDELINES According to the guidance posted on the NRC's website:

http://ruleforum.llnl.gov/nrcforum/petition.html the petition must as a minimum:

1) Setforth a generalsolution to the problem orpresent the substanceor text of any proposedregulationor amendment or specify the regulationthatis to be revoked or amended;

2) State clearly and conciselyyour groundsfor and interest in the action requested; and

3) Include a statement in support of thepetition that setsforth the specific issues involved; your views or argumentswith respectto those issues; relevanttechnical4 scientific, or other data involved that is reasonablyavailableto your; and any other pertinent information necessary to support the action sought.

To comply with your guidance, my petition will be broken out as follows:

I. SOLUTION TO THE PROBLEM A) A call for new NRC requirements for daycare centers and nursery schools; and B) These new NRC requirements should include these following protective measures; and C) Reasons for these new protective measures.

II. GROUNDS FOR AND INTEREST A) My personal experience with our nursery school; and B) My subsequent communications with area emergency management officials; and C) To address these deficiencies and insure that FEMA regulations pertaining to Radiological Emergency Readiness Planning are met.

III. STATEMENTS IN SUPPORT A) Examples of preschool children's specialized evacuation needs; and B) A survey conducted of area dayeare & nursery schools; and C) Summary.

IV. ATTACHED SUPPORT MATERIALS A) FEMA fact sheet: Nuclear Power Plant Emergency B) Salem Community Nursery School Handbook Policy C) Centers for Disease Control and Prevention Evidence of Effectiveness of Child Safety Seat Laws D) Public signatures of support for this petition 2

NOTE: For this petition's purpose the following applies to the general content:

Any reference to preschool children includes the following age groups: newborns, infants, toddlers and preschoolers between the ages of newborn to 5 years of age.

Any references to daycare centers and nursery schools are specifically referring to ALL childcare facilities that reside within the established evacuation zones around any of the licensed nuclear power station located around the nation under the control of the U.S. Nuclear Regulatory Commission.

Any reference to emergencies, emergencies evacuations, radiological incidents, radiological emergencies are referring to any radiological condition that occurs (at any of'the licensed nuclear power station located around the nation under the control of the U.S. Nuclear Regulator Commission) that poses a general threat to the public located within the established evacuation zones.

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I. SOLUTIONS TO THE PROBLEM

1) Setforth a generalsolution to the problem orpresentthe substanceor text of any proposedregulationor amendment or specify the regulationthat is to be revoked or amended I set forth general solutions to the problem with the following:

A) A call for new NRC requirements for daycare centers and nursery schools; and B) These new NRC requirements should include these following protective measures; and C) Reasons for these new NRC requirements.

A) A call for new NRC requirements.

I'm seeking new Nuclear Regulatory Commission requirements to insure all daycare centers and nursery schools are properly protected in the event of a radiological emergency.

Currently there are no federally mandated requirements that are designed to protect all daycare centers and nursery schools located in the evacuation zones around nuclear power stations. This poses great risks to all preschool children and clearly fails to meet FEMA requirements for offsite plans to adequately protect the public's health and safety.

B) These new NRC requirements should include the following protective measures:

1) Designated relocation centers established safely outside the evacuation zone for all daycare centers and nursery schools.

2) Designated transportation with emergency bus drivers for all daycare centers and nursery schools.

3) Assigned and installed approved-child-safety seats that meet state and federal laws as they pertain to the transportation of children and infants under 50lbs or the height of 4'9".

(See attached Centers for Disease Control and Prevention Evidence of Effectiveness of Child Safety Seat Laws)

4) Working rosters of designated emergency bus drivers with a means in place of notifying them in the event of a radiological emergency. This roster should be regularly checked and updated with a designated back-up driver for each vehicle and route.

5) Notification to emergency management officials, annual site inspections of daycare centers and nursery schools and inclusion of daycare centers and nursery schools in radiological emergency preparedness exercises to determine each daycare center and nursery schools' state of readiness.

6) Identification cards, school attendance lists and fingerprinting for all children who are to be transported to a relocation center to insure no child is left out or unable to communicate their contact information due to their age.

7) Educational materials for parents so they understand what is to happen and where they will be able to pick up their children.

8) KI tablets and educational materials to be stocked at all daycare centers and nursery schools located in the evacuation zone.

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9) Radiological emergency preparedness training for all daycare center and nursery school employees.

10) Inclusions of designated relocation centers in area phone directories so parents can quickly and easily find where their children are to be sent.

II) Toll-free or 911 information lines that include all daycare centers and nursery school designated relocation centers information.

12) Written scripts that include the daycare centers and nursery school designated relocation center information for uses in the public emergency broadcast system.

C) Reasons for these new NRC requirements.

1) Designated relocation centers should be required for several important reasons:

- Because of the highly susceptible nature of young children's thyroid glands to damage cause by exposure to radiation; and

- To keep frantic parents from clogging vital evacuation routes by making them backtrack into the evacuation zone to pick up their children; and

- Because planning is required for all elementary, middle, jr. and high schools, and it should be for preschoolers, and;

- To insure the health and well-being of all preschool children in the event of a radiological emergency; and

- Because preschoolers are part of the general population and FEMA has stated it's the law to properly safe guard the public in the event of a radiological emergency.

2) Designated transportation should be required for several important reasons:

- To keep frantic parents from clogging vital evacuation routes by making them backtrack into the evacuation zone to pick up their children; and

- Because most daycare centers and nursery schools have no access to public school buses; and

- To insure the health and well-being of all preschool children in the event off a radiological emergency.

3) Assigned and installed approved-child-safety seats should be required for several important reasons:

- Newborns and infants can't simply be placed on a bus seat. They can fall of and become injured or killed; and

- Federal law requires all children under 50lbs or the height of 4'9" to be placed in federally approved child safety seats (See attached Centers for Disease Control and Prevention Evidence of Effectiveness of Child Safety Seat Laws); and

- It's the only safe and legal way to transport preschool children in a moving vehicle.

4) Working rosters of emergency drivers should be required for several important reasons:

- Because most daycare centers and nursery schools have no access to public school buses; and

- To keep frantic parents from clogging vital evacuation routes by making them backtrack into the evacuation zone to pick up their children; and

- To insure the health and well-being of all preschool children in the event of a radiological emergency.

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5) Notification to emergency management officials, annual site inspections and inclusion of daycare centers and nursery schools in radiological emergency preparedness exercises should be required to insure compliance and proper implementation.

6) Identification cards, school attendance lists and fingerprinting should be required for several important reasons:

- Most children under the age of three cannot tell you their parent's names. When asked, most will say... "Mommy or Daddy". So they have no effective means of communicating their parents' names; and

- Most children under the age of three cannot tell you their home address or phone number. So they have no effective means of communicating their contact information; and

- To insure no single preschool age child is left behind during a radiological emergency.

7) Education materials should be required so parents can be properly informed.

8) KI tablets and educational materials should be required due to the highly susceptible nature of young children's thyroid gland to damage caused by exposure to radiation.

Accordingly, due to the fact that at young ages it may not be well established whether or not a child has an allergy to iodine, provision should be included for parents to give written permission (handled before any emergency - i.e. a standing order by the parent) to have the daycare administer KI in the proper children's dose to insure children's safety.

9) Radiological emergency preparedness training should be required so that school employees can properly respond to a radiological emergency.

10) Phone book listings of daycare centers and nursery schools designated relocation centers should be required for several important reasons:

- Parents may not know or have access to this information; and

- Someone other than a parent (grandparent, neighbor or friend) may be required to pick up a child due to a parent's inability to get the child during an emergency; and

- To insure the public has access to this information during a radiological emergency.

11) Toll-free and 911 information lines should be required for several important reasons:

- Parents may not know or have access to this information; and "Someoneother than a parent (grandparent, neighbor or friend) may be required to pick up a child due to a parent's inability to get the child during an emergency;, and

- To insure the public has access to this information during a radiological emergency.

12) Written scripts for the public emergency broadcast system should be required for several important reasons:

- To overt panic by providing the proper information; and

- To let parents know their children have "left their buildings"; and

- To redirect the parents efforts into evacuating themselves rather than further frustrating traffic issue trying to go opposite to evacuating traffic in an effort to get to the dayeare centers and nursery schools.

- To insure the public has access to this information during a radiological emergency.

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II. GROUNDS FOR AND INTEREST

2) State clearly and conciselyyour groundsfor andinterest in the action requested I will demonstrate my grounds for and interest in action with the following:

A) My personal experience with our nursery school; and B) My subsequent communications with area emergency management officials; and C) To address these deficiencies and insure that FEMA regulations pertaining to Radiological Emergency Readiness Planning are met.

A) My personal experience with our nursery school.

I'm a father of two preschool aged children and our family resides in the evacuation zone around the Three Mile Island Nuclear Power Station (TMI). My four-year-old daughter attends nursery school within eyesight of TMI.

We asked our nursery school's director, Lisa Viering, what their emergency evacuation plans were in case of a radiological emergency at TMI. She didn't know of any, so she checked and confirmed they had none. I called several other area daycare centers and nursery schools and found the same to be true. (See Salem Community Nursery School Handbook Policy)

B) My subsequent communications with area emergency management officials.

Upon this news I wrote to the York County Board of Commissioners and to York County Emergency Management inquiring about this alarming problem. It took over 2 months to get an answer and here is the York County Director of Emergency Management, Kay Carman's written response:

"Our office has been in contact with the Department ofPublic Welfare. This agency either licenses or regulatesdaycarecenters within the Commonwealth.

In conversation with the DPW,the question was asked !f daycarecenters were requiredto have comprehensive plansfor all emergencies along with evacuation proceduresand the answer was no, they did not. The centers were to have a procedure in caseoffire only. The only way that the DPW could mandate daycare centers to have plans would be through legislation,which is not in place at this time.'

"The role of the County is one of support to the municipality. Therefore we have been in touch with the municipalitiesyou mentioned in your correspondenceand will support their efforts to have the daycare centers develop plansfor all types of hazards. Ofcourse we are not able to mandatethat the daycare centers comply. Hopefully, as the centers see the needfor comprehensiveplanning with the assistanceof the municipalities,we will be able to get "all"daycare centers through out the County to have comprehensiveplans and notjust those centers that are within 10 miles of nuclearpowerplants."

I also received this written response from the Executive Director for the York County Department of Emergency Services, Patrick McFadden:

"Vwill attempt to again addressyour concern Re: evacuationplansfor county daycarefacilities.'

'Thejurisdictionof mandatingthosefacilitiesfalls within the Commonwealth, and we as county Govt therefore have no authority to mandate such plans be in 7

place. Therefore as stated in my previous responseto you I must concur with the Emg OperationsDept Dir.'

'Havingsaidthat, I know the York County Boardof Commissioners agree with your concern relatingto this need."

Further, according to Kay Carman, even though dayeare centers and nursery schools do not have mandated requirements for emergency evacuation planning, municipalities will help them with "comprehensive planning assistance". (Sei Salem Community Nursery School Handbook Policy)

Yet our nursery school director, Lisa Viering, has not found their help to be adequate:

"Township emergency officials referredme to Exelon (TMI operators)who they said would help me devise an evacuationplan. I called Exelon a month ago and hadnot heardbackfrom them yeL I was getting readyto call them again.

Regardless,the church has no access to a bus to transportthe 50 children who attend the ,school. Whatever plan we adoptwill involve the parentshaving to come pick up the children, which I agreedis not a workableplan. "

C) To address these deficiencies and insure that FEMA regulations pertaining to Radiological Emergency Readiness Planning are met.

Without NRC required regulations, no standard measure of adequate protection exists for daycare centers and nursery schools. This clearly fails to meet FEMA's federal requirements for offsite plans and preparedness to adequately protect the public health and safety (see attached FEMA Fact Sheet: Nuclear Power Plant Emergency):

"Since 1980, each utility that owns a commercialnuclearpowerplant in the United States has been requiredto have both an onsite andoffsite emergency responseplan as a condition ofobtaining andmaintaininga license to operate that plant. Onsite emergency responseplans areapprovedby the Nuclear Regulatory Commission (NRC). Offsite plans (which are closely coordinated with the utility's onsite emergency responseplan) are evaluated by the Federal Emergency ManagementAgency (FEMA) andprovided to the NRC, who must consider the FEMA findings when issuing or maintaininga license.'

'Federallaw establishes the criterionfor determining the adequacy of offsite planningand preparedness,L.e: "Plansandpreparednessmust be determined to adequatelyprotect the public health andsafety by providingreasonable assurancethat appropriatemeasures can be taken offsite in the event of a radiologicalemergency. "

So my grounds for and interest are to see that the NRC takes proper action to fix these deficiencies so that the Radiological Emergency Readiness Plans (RERP) meet FEMA requirements to properly protect the public by including all daycare centers and nursery schools.

But most importantly my grounds for and interest are for the safety of all preschool age children attending daycare centers and nursery schools that are not protected or accounted for by the current federal, state or county emergency plans.

Finally, the NRC should immediately create new regulations requiring emergency planning for daycare centers and nursery schools. This would expedite emergency planning amongst the states and counties with evacuation zones.

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III. STATEMENT IN SUPPORT

3) Include a statement in support of the petition that setsforth the specific issues involved; your views or arguments with respect to those issues; relevanttechnical, scientific, or other data involved that is reasonablyavailableto your; and any other pertinent information necessary to support the action sought I will demonstrate statements in support of this petition with the following:

A) Examples of preschool children's specialized evacuation needs; and B) A survey I conducted of area daycare & nursery schools; and C) Summary.

A) Examples of preschool children's specialized evacuation needs.

I have found that all public and private elementary, middle, jr. and high schools are currently required to be included in the federally required Radiological Emergency Response Plans (RERP).

Upon my written communications with West Shore School District Superintendent, Dr. Larry Sayre and Principal of Allen Middle School & West Shore School District Emergency Coordinator, Joseph A. Gargiulo I found that all of the fore mentioned schools have: designated relocation centers, designated transportation, rosters of emergency bus drivers, educational materials, state of readiness checks, inclusion in radiological emergency preparedness exercises, etc.

But, as stated and demonstrated by my many communications with state and county emergency officials, daycare centers and nursery schools do not have these same protective measures in place.

Worse yet, preschool children have very specialized emergency evacuation needs that are far more demanding than school aged children. Some of these are as follows:

1) Most children under the age of three cannot tell you their parent's names. When asked, most will say... "Mommy or Daddy". So they have no effective means of communicating their parents' names.

2) Most children under the age of three cannot tell you their home address or phone number.

So they have no effective means of communicating their contact information.

3) Infants and newborns are usually unable to walk, so they are completely dependent on others for their safe relocation during an emergency evacuation.

4) Infants and newborns have special dietary and sanitary needs.

5) Infants and newborns can easily be injured if not properly handled due to the weakness in their young spines and necks.

6) All preschool children will need to have approved-child-safety seats provided for transportation to take them safely to a designated reception center. You cant just plop a three-month-old baby on a bus seat. They can fall off and become injured or killed. More importantly, it is federal law to place all children under 50lbs or the height of 4'9" in federally approved child safety seats. (See attached Centers for Disease Control and Prevention Evidence of Effectiveness of Child Safety Seat Laws) 9

7) Unlike public school teachers, nursery school teachers and daycare center employees have little or no emergency evacuation training.

8) Infants, newborns, toddlers and preschoolers are dependant physically and emotionally on adults for their overall well being. During an emergency, these needs become extremely amplified. Planning, training and supervision during an emergency evacuation is a must.

9) Preschoolers have a higher susceptibility to damage and health risks caused by radiation exposure due to their young age.

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C) Survey of Area Daycare & Nursery Schools:

Daycare center and nursery school directors don't know what to do in an emergency...

I conducted an informal survey of area daycare centers and nursery school centers. Upon my communications I found a mixed level of confusion surrounds what the daycare centers and nursery school directors would do in the event of a radiological emergency.

1) Do you feel your facility has been provided adequate information and training to handle a radiological emergency evacuation?

- Most answered no, and said they were not aware of any evacuation plans.

- One said they had contacted county emergency officials but still didn't feel prepared.

2) Do you have copies of the radiological emergency evacuation plans and do you and your employees understand how to utilize them?

- Most said no we have not received anything.

- One said they had contacted county emergency officials but still didn't feel prepared.

3) Will parents be picking up children from your facility or will they be meeting them at reception centers like they will for public schools?

- Some said they are telling parents to pick them up.

- Some said they would take the children out themselves. When asked where? They said they were not sure... just out of danger.

- One said they were told that the county would provide emergency relocation centers (which I found to be false according to Kay Carman, York County's Director of Emergency Management).

4) If your children are to be sent to reception centers, who will be transporting them and by what means?

- The ones that answered yes said by county emergency busses (which I found to be false according to Kay Carman, York County's Director of Emergency Management).

5) If your children are to be sent to reception centers, where will they be sent?

- The ones that answered yes said they were not sure.

6) If your children are to be sent to reception centers, will they be secured into approved child-safety seats and who will provide them?

- The ones that answered yes said they were not aware if approved-child-safety seats would be used.

- When asked if they should be, they all said absolutely it's state law.

7) If the children will not be transported to reception centers, are your employees required to stay until every child has been safely picked up and have they agreed to this?

- Most said they assumed they would stay.

The results I found were very mixed. Most nursery schools and daycare centers do not think plans exist. Some are telling parents to pick their children up; some are going to try to take them out themselves (to where and how I'd like to know). And some think the county will provide school busses (even though I found this to be false).

All stated that they felt evacuation plans needed to be addressed.

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D) Summary It's my position that without new NRC required regulations no standard measure of adequate protection will ever exist for daycare centers and nursery Schools. This clearly fails to meet FEMA requirements for offsite plans and preparedness to adequately protect the public health and safety.

I summarize my statement in support by re-quoting FEMA :

"Plansandpreparednessmust be determinedto adequatelyprotect the public health and safety by providingreasonableassurancethat appropriatemeasures can be taken offsite in the event of a radiologicalemergency. "

I also summarize by re-quoting the Executive Director for the York County Department of Emergency Services, Patrick McFadden:

"I know the York County Boardof Commissionersagree with your concern relatingto this need."

And I summarize by saying that we, as a society, have a moral obligation to make sure every poss ble measure is in place to insure the safety and well being of our children.

If the NRC refuses to require these most basic protections be put in place, the NRC would be further perpetuating the improper implementation of FEMA regulations as they pertain to properly protecting the public in the event of a radiological emergency.

Further the NRC would not be doing it's most basic duty to safeguard the public; and the NRC would be grossly negligent by making claims to the American people and to the U.S. Congress that thi NRC has taken every reasonable precaution to insure the public is safe from a radiological emergency.

The community supports my concerns. (See attached public signatures of support for this petition)

I will be glad to respond to any questions regarding this submitted petition. I look forward to your cooperation and assistance in attending to my petition.

Sincerely, Lawrence T. Christian 133 Pleasant View Terrace New Cumberland, PA 17070 1-717-770-0852 12

- FEMA: FACT SHEET: NUCLEAR POWER PLANT EMERGENCY fhome Ifeedback I library I privacy policy Isearch I site help I site index]

FACT SHEET: NUCLEAR POWER PLANT EMERGENCY Since 1980, each utility that owns a commercial nuclear power plant in the United States has been required to have both an onsite and offsite emergency response plan as a condition of obtaining and maintaining a license to operate that plant. Onsite emergency response plans are approved by the Nuclear Regulatory Commission (NRC). Offsite plans (which are closely coordinated with the utility's onsite emergency response plan) are evaluated by the Federal Emergency Management Agency (FEMA) and provided to the NRC, who must consider the FEMA findings when issuing or maintaining a license.

Federal law establishes the criterion for determining the adequacy of offsite planning and preparedness, i.e: "Plans and preparedness must be determined to adequately protect the public health and safety by providing reasonable assurance that appropriate measures can be taken offsite in the event of a radiological emergency."

Although construction and operation of nuclear power plants are closely monitored and regulated by the NRC, an accident, though unlikely, is possible. The potential danger from an accident at a nuclear power plant is exposure to radiation. This exposure could come from the release of radioactive material from the plant into the environment, usually characterized by a plume (cloud-like) formation. The area the radioactive release may affect is determined by the amount released from the plant, wind direction and speed and weather conditions (i.e., rain, snow, etc.) which would quickly drive the radioactive material to the ground, hence causing increased deposition of radionuclides.

If a release of radiation occurs, the levels of radioactivity will be monitored by authorities from Federal and State governments, and the utility, to determine the potential danger in order to protect the public.

What Is Radiation?

Radiation is any form of energy propagated as rays, waves or energetic particles that travel through the air or a material medium.

http://www.fema.govllibrary/radiolo.htm (1 of 6) [6/312002 9:42:34 AM]

DAY AND TIME OF CLASS:

INSURANCE:

3-year-old class Tuesday, Thursday - 8:45 - 11:15 a.m.

Your child Is Insured by the church over and above hls/her own personal Wednesday - 8:45 a.m. - 12:45 p.m. Insurance.

Combined 3&4-year-old class 4-year-old class Tuesday, Wednesday, Thursday - 9:00 - 11:30 a.m. On school tips, a parent driver Is Insured over and above your own personal Insurance. Pennsylvania law requires that each child must be individually seat belted on all school trips.

September through May 36-week session PLAY CLOTHING:

SNOW DAYS AND CANCELLATIONS:

Please dress your child in washable, comfortable pay clothes that he or Our families live Ina wide area and during the winter months it sometimes she can manage himselfiherself. The children will have many different art and play activities. Pants with elastic waist bands are preferred unless becomes necessary to close school because of severe weather your child can manage his snaps, belts and zippers. Sneakers are good conditions. If the West Shore School District doses school for the day, footwear for nursery school activities.

Nursery School will also be dosed for the day. Ifthe West Shore School District delays school for one (1) hour, Nursery School will have a one hour delay in starting time with dismissal at the regular time. Ifthe West Shore School District has a two (2) hour delay, Nursery School times will ( OUTDOOR PLAY:

be as follows: 3-Year-Old Program from 10:45am - 12:1 5pm; 4-Year-Old Outdoor play provides so many wonderful experiences for the children, Program from I 1:00am - 12:30pm: Wednesday 314-Year-Old Program and we do go outdoors if at all possible. So please dress your child from 10:45am - 1:15pm. A maximum of 3 snow days will be made up if accordingly (I.e. remember a Jacket or sweater If needed.)

necessary. Unfortunately, no refunds can be given for missed school days.

( THREE MILE ISLAND EVACUATION POUCY:

We are currently gathering information for an evacuation policy for the Nursery School in the event of a TMI emergency. We will keep everyone updated as further Information becomes available.

Contact:

Stephanie Zaza, MD, MPH Phone: 770-488-8189

,COMMUNITY! Services E-mail: epogda@cdc.gov Centers for Disease Control and Prevention Preveniive Epidemiology Program Office At 1E,E'0DENCE E,ýýSED RECCIA VENRAT IN 1-3 tý SYSTEM AT IC RTVID.A.-ý,--

Evidence of Effectiveness of Child Safety Seat Laws Motor vehicle-related injuries kill more children than any other single cause in the United States. When correctly installed and used, child safety seats reduce the risk of death by 70% for infants and 47%-54%

for toddlers and reduce the need for hospitalization by 69% for children aged 4 years and younger.

CDC recently conducted a systematic review of studies of laws requiring use of child safety seats and found them to be effective in decreasing fatal and nonfatal injuries, and in increasing child safety seat use This review appears in a November, 2001 supplement to the American Journal of Preventive Medicine:

Zaza S, Sleet DA, Thompson RS, Sosin DM, Bolen JC, Task Force on Community Preventive Services.

Reviews of evidence regarding interventions to increase use of child safety seats. Am J Prev Med. 2001: 21 (4S); 31-47.

Based on this review, the Task Force on Community Preventive Services strongly recommended implementation of such laws.

Background on laws requiring use of child safety seats

" All 50 states currently have laws requiring children traveling in motor vehicles to be restrained in federally approved child restraint devices (e.g., infant or child safety seats) appropriate for the child's size and age.

"* State laws vary vWidely in defining the age, weight, and/or height, of children affected by the law, as well as the enforcement provisions and penalties.

" Although enforcement provisions and penalties also vary widely from state to state, enforcement is primary. Drivers can be stopped solely for failing to restrain children as required under the law.

Findin~gs from the systematic review of child safety seat laws Among the nine qualifying studies:

"* Laws decreased fatal injuries by a median of 35%

"* Laws decreased fatal and nonfatal injuries combined by a median of 17%

"* Laws increased child safety seat use by a median of 13%

"* Among the studies that evaluated the laws' effects on injury rates, researchers found no differences in the effect size based on the age of children who were required to be in safety seats.

About the Guide to Community Preventive Services (the Community Guide)

The Task Force on Community Preventive Services is a 15-member, nonfederal group with expertise in public health policy, behavioral and social sciences, and epidemiology. The Community Guide assesses the effectiveness of a broad range of population-based interventions to improve the health and safety of communities. Staff at CDC support the work of the Task Force and coordinate the day-to-day development and dissemination of the Community Guide. More information can be found at http://www.thecommunityauide.org

she's not complaining about being left out of the evacuation plans...

but you should be currently day care centers and nursery schools are not federally required to have ANY radiological emergency evacuation plans

Day Care & Nursery Schools Have No Evacuation Planning Requirements.

Currently day care centers and nursery schools are not federally required to have ANY radiological emergency evacuation plans.

Without new NRC requirements designed to insure all day Until the U.S. Nuclear Regulatory Commission creates new regulations requiring emergency planning for day care care centers and nursery schools are properly planned for, centers and nursery schools none will ever exist.

children will continue to be left without any:

These oversights clearly fail to meet FEMA requirements

"*designated relocation centers a designated transportation for offsite plans, and preparedness to adequately protect the

"*approved-child-safety seats a rosters of emergency bus public health and safety.

drivers u planned educational materials a notification of state of readiness a inclusion in radiological emergency So please help us by signing this petition supporting our preparedness exercises, etc. efforts to fix this dangerous oversight.

We the undersigned hereby support this petition to the U.S. Nuclear Regulatory Commission seeking new Nuclear Regulatory Commission requirements to Insure all day care centers and nursery schools are properly protected inthe event of a nuclear incident or terrorist attack at a nuclear power station.

Signature Address Phone Number I I I. I-il i I t

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__ __I_ _ I I t I I

_____ I ________ I____I

We the undersigned hereby support this petition to the US. Nuclear Regulatory Commission seeking new Nuclear Regulatory Commission requirements to insure all day care centers and nursery schools are properly protected inthe event of a nuclear incident or terrorist attack at a nuclear power station.