ML20070L543
| ML20070L543 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/24/1982 |
| From: | Horowitz S PARENTS CONCERNED ABOUT INDIAN POINT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8301030172 | |
| Download: ML20070L543 (5) | |
Text
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J UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION' J
C0t KE TET:
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'82 DEC 30 All:39 In the Matter of
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CONSOLIDATEDEDIS0NC0!NANYOFNEWYORK c et Nos. 50-247 SP (Indian Point Unit 2)
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50-286 SP
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POWER AUTHORITY OF THE STATE OF NEW YORK.
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Dedenber 24, 1982 (Indian Point Unit 3)
)
D PARENTS CONCERNED ABOUT INDIAN POINT Proposed Revised Contentions on Commission Questions 3 and4 PARENTS CONCERNED ABOUT INDIAN POINT is prepared to prove, its original contentions:
I.
Children within the ten mile plume exposure. pathway emergency planning zone are particularly susceptible to 'the phys-ical effects of radiation,and to the psychological trauma of a disaster, and are 'not adequately protected by the' Radiological Emergency Response Plan.
II.
Children outside the 10 mile EPZ are particularly' susceptible to the physical ef fects of radiation and to the psych-ological trauma of a disaster and are not adequately protected by the Radiological Emergency Response Plan.
III.
Adequate consideration has not been given to parental and child behavior and to family decision malting, patterns in the emergency planning process.
(See bases in CO.NTENTIONS 0/ PARENTS CONCERNED ABOUT INDIAN POINI, undated)
If these original contentions are not reinstated, PARENTS suggests that the MEMORANDUM AND ORDER of April 23, 1982, formulating Contentions, Assigning Intervenors, and Setting Schedule, is a good working document and should be adopted f or the hearings on emergency planning.
Docho!hohjj7 r
PDR i*
Pagn 2 i
PROPOSED CONTENTIONS BASED ON ICE dORANDUI4 AND O'RDER, ' APRIL 23, 1982 I.
Emergency planning for Indian Point Units 2 and 3 is inade-quate in that the presenfc state of preparedne'ss does not fulfill any of the 16 mandatory standards set forth in 10 C.F.R. 50:47(b),
nor doestit meet the standards set forth in' Appendix E to 10 C.F.R.
II.
Emergency Planning Ior Indian Point Units 2 and 3 is inadequate in that the plans make erroneous assumptions about the response of the public and of utility employees during radiological emergencies.
III.
The present estimates of evacuation times, based on NUREG-0654 and studies by CONSAD Research Corporation and by Parsons, Brincker-hoff, Quade and Douglas, Inc<, are unreliable.
They are based on un-proven assumptions, utilize unverified methodologies, and do not re-flect tl.e actual emergency plans.
IV.
The licensees cannot be depended upon to notify the proper authorities of an emergency promptly and accurately enough to assure effective response.
V.The Emergency plans and proposed protective action do not adequately' take into account the full range of accident. scenarios and meteoro-logical conditions for _ Indian Point Units 2 and 3 V.
The problems of cvacuating children from threatened areas have not been adequately addressed in the present emergency plans.
BASES 1.
Some parents do not l.have transportation available at all times.
Parents who hust evacuate by public transportation will have special problems.
2.
The reception centers designated to receive our children have not been adequately prepared to meet even basic needs and certainly not emergency needs.
3.
Public officials are not convinced that the evacuation of school children by bus will work.
4.
Families and people who care for children with special needs cannot successfully evacuate.
5 People who are directly responsible for carrying o~ut'" emergency
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plans and ensuring the saf ety of children have not been adequately prepared and have expressed doubts about their willingness to parti'ipata c
including day care center operators, babysitters, bus drivers, police, ambulance corps personnel, and fire fighters.
6.
Special facilities will have extensive problems in attempting
Pag 3 3 evacuation of 1 children.
These problems have been identified b'y teachers, school administrators, school bus personnel, off-premises program supervisors, and school health personnel, and have not been corrected in any revisions.
Other special fa'cilities with special evacuation problems include camps, parks, public after-school recrea-tion programs, private after-school recreation programs, and churches.
7 Children home alone will be at special risk in case of an emergency at indian Point.
8.
Lack 01 coniidence in the plan and in the ability of o ficials te implement the plan will~ hamper any emergency response.
Parents will not obey the school evacuation portion of the plan.
Parents have not instructed babysitters on how to care for their children in a radiological emergency.
9 The evacuation effort will be delayed because parents have children. in different schools, and because there are children who live outside the 10 mile EPZ but attend schools within the 10 mile EPZ.
10.
The-evacuation plans regarding adolescent children and regarding very small children are unrealistic and inadequate.
11.
In order for any evacuation; plan to work it must be thoroughly explained to all t,he par.ticipants and rehearsed, but such preparations will be damaging to the emotional lives an'd healthy development of children.
12.
Psychological and social damage will result'if families are
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separated during an evacuation.
V1.
The road system in the vicinity of the Indian Point plant is inadoquate for timely evacuation.
VII.The plume exposure pathway EPZ should be expanded from its present 10 mile radius in order to meet local' _ emergency response needs and capabilities.
BASES 1.
Everyone within the four counties should at lease receive an emergency planning brochure and other emergency planning information so that they will be prepared to render assistance to..the. evacuees.
School districts shopld not be divided; every family that has children at a school designated for evacuation should also be evacuated.
2.
Many people outside the 10 mile EPZ will self? evacuate.
These ad hoc protective measures could hamper the evacuation of those within the 10 mile radius.
There must be an evacuation plan for them.
Page 4 3
No information las beene.distibuted on how to protect a~ gainst radiation exposure from contaminated food and_ water.
VIIr.
The following specific, feasible off-site procedures should be taken to protect the publics a)
Potassium Iodide should be provid'ed in an appropriate form for all residents in the EPZ b)
Adequate sheltering capability should be provided for all residents in the EPZ r-c)
License conditions should prohibit power opeastion of Units 2 and 3 when the roadway network becomes degraded because of adverse weather conditions.
d)
The roadway network should be upgraded to permit suc-cessfyl evacuation of all residents in the EPZ before the plume arrital time.
5E.
There are no feasible off-site emergency procedures which can adequately protect the public.
X.
The emergency plans should be upgraded by taking account of special groups with special needs in emergencies.
In' particular, provision must be made for evacuating persons who' are dependent upon others for their mobility.
XI.
Specific steps must be taken by NRC, State and local officials to.. promote a public awaren6'ss that nuclear, power plant accidents with substantial off-site risks are possible at Indian Point.
XII.
A maximum acceptable level of radiationnexposure for the public must be established before any objective basis will exist for adequate emergency planning.
XIII.
The present emergency planning brochures and 'present means of alerting and informing the population of an emergency do not five adequate attention to problems associated with persons who'are deaf, blind, too young to understand the instruction's., or who do not speak English.
BASES 1.
{ncomplete notificatinn o2 the public by brochure and siren in case of a nuclear emergency will result in failure of the emergency plan.
2.
No special provisions have been made for notification "of citizens who are dicabled by virtue oi being deaf or elderly.
3 People who spend a considerable amount of time within the 10 mile EPZ but live elsewhere would not know what to do in the event of an emergency.
4.
The emotionally and developmentally disabled, as well as ch.'.ldren,
Page 5 are incapable of effectively understanding the' brochure.
Parents would like to offer for consi.deration another contention based on iEMA.'.s evaluation procedure and the fact that FEMA proposes to make an evaluation of preparedness after the March 9, 1983, exercise:
XIV.
Preparedness should be demonstrated by the willingness and ability of emergency workers in the field, by commitments in the form of letters of agreement from all emergency response agencies inchuding schools, bus companies, fire departments, ambulance corps, and local Red Cross chapters, and by the approval, in the form of signatures on the plan, of elected officials of local governments which will be called upon to implement the plans.
BASES
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l.
The state has forwarded no letters of agreement to FEMA except one from the national Red Cross.
2.
None of the four County Chief Executives have " signed off" on the plans.
3 No local government officials have signed off on the plans.
4.
The annual exerciseri'5 not a measure,of preparedness because it is extremely limited and because the scenario is well. rehearsed.
The excercise does not measure the ability to mobilize on the vase scale which would be required in a real radiological emergency and it does rot measure the commitment of the emergency w.orkers or the human re-sponse to such a stress.
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f Respectfully silbmitted, l
CERTIFICATE OF SERVICE i
i I hereby certify that copies
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of this document have been I
mailed to the minimal service Parents Chbcerned Aboud list on this 27th day of Indian Point De cembe r, 1982.
Ge s
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