ML050960545
| ML050960545 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/02/2005 |
| From: | Burton N Connecticut Coalition Against Millstone |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 69FR71437 00026 | |
| Download: ML050960545 (19) | |
Text
-S CONNECTICOUT COALITION AGAINST MILLSTONE www.mothballmilistone.orp March 2, 2005 Rules and Directives Branch
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Division of Administrative Services Office of Administration 3
Mailstop T-6D59 U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Re: Millstone Nuclear Power Station/Draft Environmental Impact Statement
Dear Sirs:
The Connecticut Coalition Against Millstone submits herewith
-- preliminary comments concerning the draft Environmental lmpacti Statement (EIS) which the NRC staff has prepared in support of relicensing of Millstone nuclear reactors Units 2 and 3 to extend their terms to the years 2035 and 2045 respectively. These comments will be supplemented with a separate filing with attachments.
The Coalition strongly opposes Millstone relicensing.
The data available to the U.S. Nuclear Regulatory Commission in its environmental review establishes a clear link between Millstone's radiological and chemical discharges to the environment and major health effects in the surrounding community.
The data reviewed by the NRC is alarming.
The data strongly suggests - and indeed does so almost to a certainty - that Dominion Nuclear Connecticut, Inc. is operating and will continue to operate the Millstone Nuclear Power Station in violation of NRC regulations requiring limiting doses to the public of 15 millirems per year to any organ.
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Put another way, the data strongly suggests that Dominion's Millstone daily operations exceed the permissible dose of radiation to the public and will continue to do so during the proposed relicensing period.
Based on Dominion's own reporting of radiation sampling in the environment, the Coalition believes the available data reviewed by the NRC for the years 2001, 2002 and 2003 prove that routine operations of Millstone are in violation of federal health standards and are illegal.
By its own admission, the NRC confined its review of Millstone radiological releases, for Environmental Impact Statement purposes, to the years 2001, 2002 and 2003. ("Radioactive Waste Management Systems and Effluent Control Systems 2.1.4," DEIS at 2-9) (No explanation is provided in the DEIS as to why the years 1970-2000 and the year 2004 - with the most current data - were excluded from review.)
The Annual Radiological Environmental Operating Report submitted by Dominion Nuclear Connecticut, Inc. to the NRC for the year 2001 - one of the few reports the NRC specifically identified that it had reviewed in its EIS procedure - contains the following information:
On September 19, 2001, a concentration of strontium-90 of 55.5 picoCuries per liter (pCi/I) was measured in a sample of goat milk taken from a location 5.5 miles north-northeast of the Millstone Nuclear Power Station. The uncertainty factor reported was plus or minus 5.3 pCi/L.
A concentration of 55.5 picoCuries per liter is an "extremely large concentration, close to twice the highest concentration measured in Connecticut pooled milk at the height of nuclear weapons testing in 1963 of 23 pCi/L," according to a report dated March 1, 2005 by Dr.
Ernest J. Sternglass, Professor Emeritus of Radiological Physics at the University of Pittsburgh School of Medicine and an acknowledged pioneer in the field of the effects of low-level ionizing radiation on living cells. The report appears annexed hereto as Exhibit A.
2
Moreover, according to Dr. Stemglass, since the measured value is ten times as large as the measurement uncertainty, "this is an extremely significant result, with an astronomically small chance that it is a statistical fluctuation."
Put into perspective, an individual drinking two eight-ounce glasses of the strontium-90-contaminated goat milk on a daily basis would receive a maximum permissible dose of radiation - under NRC guidelines - within 30 days.
This assumes no other radiological contamination of the milk.
However, strontium-90 never appears alone in the environment.
When the radiological effects of identified concentrations of radionuclides also reported in the same goat milk sample - cesium-134, cesium-137, iodine-131, barium-140 and others - are considered, the effect is even more damaging and far less milk would need to be consumed over fewer days before the maximum permissible radiation does established by federal law would be exceeded, according to Dr. Sternglass.
"The dose to bone or the bone marrow when other fission products are present is some 5 to 6 times greater than from strontium-90 alone, and the Dominion reports for goat milk show significant concentrations of other fission products, such as cesium-137, in significant concentrations," Dr. Sternglass states in his report, Exhibit A.
"Using the NRC NUREG 1.109 dose factor of 0.0172 mrem/pCi/l
[millirem] from Table A-5, a mere 2.4 pCi/l daily intake results in the maximum permissible dose to any organ of 15 mrem per year set by NRC guidelines, 23 times the amount measured in a single liter,"
according to the Sternglass report.
Attached to Dr. Sternglass' report are measurements, reported to the NRC by Dominion, of strontium-90 in goat milk sampled at locations within 5 miles of Millstone during the years 2001, 2002 and 2003.
3
The reported samples of measurements show concentrations of 13 to 14 pCi/I on other days during the three-year period. According to Dr. Sternglass, these are also significantly high readings since strontium-90, concentrating in milk due to atmospheric nuclear weapons testing which ended in 1980, has declined to less than 1 pCi/I in areas far removed from any nuclear reactors.
Since the samples are collected by Dominion only twice a month, it is unknown whether actual concentrations on other days exceeded the levels reported.
In 1997, Millstone's previous owner, Northeast Utilities, persuaded the NRC to permit it to discontinue sampling for strontium-90 in its air filter monitoring program. As the 1997 Annual Radiological Environmental Operating report states:
Section 4.5 Air Particulate Strontium (Table 5)
Table 5 in past years was used to report the measurement of Sr-89 and Sr-90 in quarterly composited-air particulate filters.
-These measurements are not required-by the Radiotbgica[
Effluent Monitoring Manual (REMM) and have been discontinued. Previous data has shown the lack of detectable station activity in this media. This fact, and the fact that milk samples are a much more sensitive indicator of fission product existence in the environment, prompted the decision for discontinuation. In the event of widespread plant related contamination or special events such as the Chernobyl incident, these measurements may be made.
Strontium-90 is among the most deadly byproducts of nuclear fission. Once ingested, its highly-energetic electrons damage and cause mutations in nearby cells. Exposure to low levels of strontium-90 and other bone-seeking radioactive chemicals routinely released by nuclear power plants does not merely increase the risk of bone cancer or leukemia, but it weakens the immune defenses provided by the white cells of the blood that originate in the bone marrow. See Declaration of Ernest J. Sternglass (August 8, 2004) submitted to the NRC in In the Matter of Dominion Nuclear Connecticut, Inc., Docket No. 50-336-LR, 50-423-LR, ASLBP No. 04-824-01 -LR, annexed hereto as Exhibit B.
4
"As recently shown in the 2003 report by the European Committee on radiation Risk, numerous epidemiological and laboratory studies have shown that the risk of cancer and other diseases produced by local internal doses to critical organs from fission products that are inhaled or ingested have been underestimated by extrapolation from high external doses by factors of hundreds to thousand of times,"
according to the Sternglass report, Exhibit A.
uThis explains why it now appears that releases from nuclear plants, often acting synergistically with other environmental pollutants, are a major neglected reason for the recent rise of illness and deaths both among newborns and the elderly observed in the U.S. in the last two decades, as also discussed in the ECRR report,"
according to Dr. Sternglass. Id.
"For these reasons, it is my professional opinion that the Millstone Nuclear Plant should not be relicensed," Dr. Sternglass stated. In his report, Exhibit A.
--The Coalition has previously submitted, in these and the related Atomic Safety and Licensing Board proceedings, documentation from Joseph Mangano and Michael Steinberg which links the Millstone radiological effluent releases - including strontium to significant negative health consequences in the community. These documents are incorporated by reference herein.
CONNECTICUT COALITION AGAINST MILLSTONE Niancy;urton Please address correspondence to:
Nancy Burton 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 5
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Memo' Date: 03 From:
Subject I have re samples Environm carcinogen continues Thusin 55.5 pico for Me PCIIL. Th measured 23 PCI/L, Company large as the astronolrcc To put this mreMIPCI permissible amount mm
- Moreover, present for concentrati As the encl found on o1 PCL/L.
- Moreover, bone marro from Sr-90 other fissioi Tle high cc possibility I other than I Millstone.
dun to: Nancy Burton test I. Sternglass, Ph. D.
9llstone Relicensing Lntly had the opportunity to examine the levels of radioactivpyin goat milk ported by Dominlum Nuclear Connecticut, Inc. in their Annual Radiological ntal Operating Reports and found that highly significant concentrations of fission products were measured, indicating that the Millstone nuclear plant represent a major health hazard to the people of the area enclosed copy of Table 8 of the Report for the year 2001, a concentration of nes per liter (PCI/L) of milk of Strontiwn-90 was reported for Location 22 le measured on September 19, 2001, with an uncertainty of plus or minus 5.3 is an extremely large concentration, close to twice the highest concentration Connecticut pooled milk at the height of nuclear weapons testing in 1963 of can be seen from the enclosed Figure 6-1 prepared by the Dominion r the period 1961 to 1993. Moreover, since the measuredzvalue is ten times as measurement uncertainty, this is an extremely significant result, with an ly small chance that it is a statistical fluctuation.
to perspective, using the NRC NUREG 1.109 dose factor of 0.0172 iom Table A-5, a mere 2.4-PCI daily intake results in the maximum dose to any organ of 1 5mrem per year set by NRC guidelines, 23 times the sured in a single liter.
ince strontium-90 has a physical half-life of 28 years, it must have been number of days that month. In fact, only 16 days at the measured n of 55 PCI/L are sufficient to reach the permissible dose.
Ised samples of measurements show, concentrations of 13 to 14 PCI/L were er days, again significantly higher than the measurement uncertaintY of 1-2 i s discussed in the United Nations UNSCEAR reports, the dose to bone or the V when other fission products are present is somne,5 to 6 times greater than lone, and the Dominion Reports for milk show significant concentrations of a products, such as Cesium-137, again significant concentrations.
centrations of Sr-90 and other isotopes measured clearly exclude the at they are due to past nuclear bomb-tests. No other sources of Sr-90.exist e fission of Uranium, so the, measured values mepreent releases from
Memorat Date: 03/
From: En
Subject:
)
I have rec samples r Environm carcinogei continues dum, to: Nancy Burton
)1/05 est J, Stemglass, Ph. D.
lillstone Relicensing
,nty had the opportunity to examine the levels of radioactivip-in goat milk ported by Dominium Nuclear Connecticut, Inc. in their Annual Radiological ntal Operating Reports and found that highly significant concentrations of ic fission products were measured, indicating that the Millstone nuclear plant o represent a major health hazard to the people of the area.
___7 Tbus, in th~enclosed copy of Table 8 of the Report for the year 2001, a concentration of 55.5 picoC iries per liter (PCI/L) of milk of Strontium-90 was reported for Location 22 for the sanrrle measured on September 19, 2001, with an uncertainty of plus or minus 5.3 PCI/L. Thi is an extremely large concentration, close to twice the highest concentration measured i : Connecticut pooled milk at the height of nuclear weapons testing in 1963 of 23 PCIJL, 4 can be seen from the enclosed Figure 6-1 prepared by the Dominion Company kr the period 1961 to 1993, Moreover, since the measuredvalue is ten times as large as th measurement uncertainty, this is an extremely significant result, with an astTonomic fIly small chance that it is a statistical fluctuation.
To put this into perspective, using the NRC NUREG 1. 109 dose factor of 0.0172 mrem!PCI.eom Table A-5, a mere 2.4 PCI daily intake results in the maximum permissibl] dose to any organ of I 5nrem per year set by NRC guidelines, 23 Yimei the amount m4sured in a single liter.
Moreover, !ince strontium-90 has a physical half-life of 28 years, it must have been present for number of days that month. In fact, only 16 days at the measured concentrati In of 55 PCI/L are sufficient to reach the penmissible dose.
As the enclosed samples of measurements show, concentrations of 13 to 14 PCIIL were found on oter days, again significantly higher than the measurement uncertainty of 1-2 PCI/L.
Moreover, is discussed in the United Nations UNSCEAR reports, the dose to bone or the bone marro v when other fission products are present is some, 5 to 6 times greater than from Sr-90 Lone, and the Dominion Reports for rnilk show significant concentrations of other fissio* products, such as Cesiuwn-137, again significant concentrations.
The high c lcentrations of Sr-90 and other isotopes measured clearly exclude the possibility hat they are due to past nuclear bomb-tests. No other sources of Sr-90.exist other than t 1e fission of Uranium, so the measured values repreent releases from Millstone-I I
I I
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'1 7 I 21:09 4126816251 PAGE As tecen#
numerou othe dis
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as also di For these not be reli Ernest J. S Professor University Home addx University 4106 Fifth Pittsburgh, 02 y shown in the 2003 report by the Europcan Committee on Radiation Risk, epidemiological and laboratory studies have shown that the risk of cancer and tses produced by local internal doses to critical organs frcim fission products Waled or Ingested, have been underesthmated by extrapolation from high
,ses by factors of hundreds to thousands of times. This explains why it now it releases from nuclear plants, often acting synergistically with other tma pollutants, are a major neglected reason for te recent rise of illness and i among newborns and the elderly observed in the U.S in the last two decades,
,ussed in the ECRR report.
- nasons, it is my professional opinion that the Millstone Nuclear Plant should 4nsed.
nglass, Ph. D.
mezitus of Radiological Physics f Pittsburgh School of Medicine s:
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IUNTED STATES OF AMEICA NUCLEAR REGULATORY COMMISSION BEPORE THE ATOMIC SAFEMY AND LICENSING BOA In the Matter of DOMINION NUCLEAR CONNECTICUT, INC.: Docket Nos S0-423-LR RD 50-336-LR, (Millstone Nuclear Power Station, Units 2 and 3)
- ASLBP No. 04-824-01-LR DECLARATION OF.ERNEST L STERNGLAS5 L Ernesti. Sen~hm, do hebv declare as follows:
I. I am above the age of eighteen (18) yzars and I believe in the obligation of J
- 2.
lreside at4601 lFh Avenue in Pittsburg Pennsylvani, 15213.
3 1 submit this declIaration in suppt of Connecticut Coaitifo Against the biovc rerencedmatter.
- 4. I am Prfessor Emeritus of Radiological Physics at &f University of Pi Medicine and have written and published extensively in the area of low-level ra hcalth, and abo the adrerse effect of radioacive emissions from the Mills Station in particular.
- 5. 1 am the author of the book oSect Fallout Low-Levd Radiatiom firm Mle lsland" piblished by Melraw-Mili in 1981, of the Mrview article vEnviro Human Health" pubfished by the Univclsity of Caiffornia Arss in 1972, and tihe Mortality Qanges Around Nuclear Facilities in Connecticut" pubusW in PRdi Human HealLk Pcedings Of a CongSional SeminarFebrUy 10, 1978, b PolicY Institute in WaWOD DC. Ile fact and statements contained in these incorated by reference herein as references 1, 2 and 3 reqpechvely.
- 6. 1 have published a serlu of paps on bkkC of low-level environmew humnan health and developmrn proded by nuclew weapons tes auzd rctor rel TE 39Vd an oath.
nDe terventioi~n gh Schoolof 4tion mad human NuclearPower rNmai to The-tntal Radiation and rlicle Cancer 6cn Standards and he Enronneaw blicafl~ns ame riation on ases for 4 Last
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I forty years, and have testified on this subject at heaings held by the U.S. Con Academy cf Sciences, State Legislatures and U.S. Government legulatory Al ibis subject.
- 7. It is my professional opinion that the radioactive rleases fmum the Millbu Statio since its startup in 1970 have caused and will continue to cause excess i birthweight, leukewia and cancer as well as increased rates of both chronic and the towns amund Mistone as veUl as in New London County and Cowiecticu I
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- 8. According to the NRC publication "Radioactivc Materials Released From Plants" (UREG CR -2907), by 1987 Millstone had released a total of 32 CQu Iodine and Particulates into the air which inlude the highly ogenic Strunt
-131, together with 6.7 million Cuties of Total FlSison and Activation gases suc Krypton, and the highest liquid releases of Mixed Fission and Activation Podu~
plant in the United States, namny 581 Curies or 581 trillion picoCuies, te and drinling water,
- 9. In a single year, 1975, Milstone released a record high of 9.99 Curies of Partcuates into fe air, more than twice as high as he 4 Curies releasedo 1971, togeher with 29.7 mnillion Curies of Total Fission adAtivatonljases, liquid Mixed Fission and Activation Products into Long Island Sound, also a nudear eactrs
- 10. Between startup of Millstone in 1970 and 1975, as shown in the 1978 M cancer mortality rose 58% in Waterford where the reactor is localed, 44% in Ne the north-eas, 27%in New aven 30 miles to the west, 12% for the Stteatc whole, 8% mi nearby Rhode Island, 7% in Massachusetts and 1% in New H actually declined by 6% in the most distant New England state, Mahex folilo Strovdurn-90 in the milk shown in the same report.
- 11. As shown in Table 9 of reference (3), while the Strontium-90 co tai declined for the U.S. as a whole between 1970 and 1975 fran 8 picoCuries per it rose fom 9.8in 1970 to a high of 1bS.8 in 1
in 1974 near theMil remaining at 10.7 by 1975. Ihis is far in excess of the U.S. average of 3 pCi4, significant contribution to the local milk from bcb test fallout by France and until 1980.
, the National tcies 4s an expert on Nuclear Power moant rtality, low etous diseases in a whole, uclear Power of rdioactive
-90 and Iodine as Xenon and of any nuclear of conem in mil d
and After s up i n aid 199 CQiiesrf
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- 12. As shown in Tble 10 of nfcrue (3) the calculated yearly radiation dos due to the excess Strnium-90 within 10-s15 miles of the plant in excess of the U.S. rose from 33 millirem per year in de rist full year of operation to 204 mr nea fthe times the nomal background level of 70 mrem/yr mn Connecticut
- 13. These doses due to Stroutium-90 alone may be compared with the 15 wr permitted under current NRC regulations, the 2 mrem produced to bone marroi X-g of a -c and the 8) m rn/)Tto a dereloping fetus found toroduce a of childhood leukemia in the studies of Dr. Alice Stewart cited in Refeene 7 exposure in the others womb to X-rays in the first three mnths of
- 14. These considerations, later supported by the more recent studies of Sto baby teeth together with effect on cancer mcidence and infant motality as repo submitted in the prcsent case and referred to here as reference (4) provide overv the eistence of a causml reaonsbip between the abnormally high levels of S and the pattern of cancer changes at various distances from the Millstone plant
- 15. The j~dse=e of a d c ausal relatonship betweenStniium-90 reas eact and-an increased isk of cancer is very y
tronglysuored by ithe finl -
Mngano (4) ta baby teeth of cild n diagnosed with cancer have dose to do concentration of Strnfium-90 than children bom the sane year and in the same has led la a lawsuit having been fed in loida against the Flwida Power and family of a child wit a veay high Strontium-90 tooth concentration seeking co which a fedm-al judge nled to be of sufficiet merit to go to tril in 2005, despit defendant to have it dismisse (5).
- 16. As poinx-d ot in reference (3), this conclusion is still futher sWppor I
types of cancer hat rose most strongly in the Connecticut area neam the Mston exacly those dhat have been found to be most sensitive to radiaton in eafiier international standard setting organizations, namely those that increased the mo respiratory cancers (37%), brtast cancer (12%), and pancreatic cancer (32%)
- 17. Likewise, further support for a causad relationship of nuclear plant reeal4 effect is p ided by the f cid ba uso et L(S) citedin referece (1) l o showed a much greater rise in women than in men, namely 17% for white wom 2 to bane of a child early dose for the me by 1974, to any organ in a typical chest lmof therate refere (3) for umn90 measred in ted by Magano belming evidence for Oium-90 in tire milk fromn nuclear described by maea. Thi finding g compan by the peaution, a suit effoam of the v the fact that the Nuclear Flant are ies by national and by 1975, such as and advme health cancer deahs I and only 11% fcr
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i ihitc mdes. This same difference between males and females was found by investigators for atomic workers at the Hanford Nuclear Plants exposed to low internal exposures to critical organs due to ihaed and ingested rdioacive elem released by Millstone over a peiod of years, together with protrated external e gamma rays prodced by fission products accumulated on the grund, rather t14 ray exposures used in diagnostic' cedures.
- 18. A renewed rise in infant mortality in the six towns nearst Millstone too decine by 18% when all three units had been shut do"n for most of 1996-97 as of the 2004rpoxtby Man=
o(4), with asmaler decline of 3.1% in 19W99 followed by a rise of.8% in 2000-01. This is very stg evidence indica smaller reeases firom the two maining PWR tpe of reactors continue to adYe of the newborn so ttat thee can be no safe opeation of any cxisting type of nu developing childru on whom the future of our nation depends
- 19. The much greater risk to human beah from radioactive gases and partict ingested and cacertrate in certain critical organs such as the bore marw aor glands such as the pituitary gland targeted by the igbly radioactive daughter 90,- the elemnent Yttrium-90tliathas diffent=Uehemca properties and leaves the in oft tisues. This results in very high local doses to both: the bone mwnow anL produig glands over long penods of time that greatly exceed the Whole-body cancer and other adverse effects on health hundreds to thousands of times great expected by a linear extrapolation to low doses of the risk from ahmt extewal e received by the survivors of Mroshima and Nagasaki or individalLs exposed to do not concentrate in specific organs, as described in the ECRR report (6).
- 20. It is important to note that exposure to low levels of Strontium-90 and o radioactive chemicals routinely rdeased by mnclear plants that resemble CalciO increase the risk of bone cancer or leukemia, but they weaken the immune defer
- white cells of the blood that oriinate n the bone marrow. As a result the rate of c all over the body normally held in check by white cells is increa and the def infectious diseases swch as influenza, pneumonia and AIDS are lowered in infant mortality due to all causes combined as discuss-d in refernices (1X2X3) i
- 21. Unfortunately for the protection of human hea, the operators ofuc Millstone are no longer required to measure Sturrum-90 in the milk, the stil, and his co-l of both ts imilar to those urea from toveryShortX-place after a sharp described in Table 9 relative to 1994-95, mt even the much edy affect the health Lear plant for te s that are inhled or hxmce prF uiag duct of Strontium-One to concentrate the critical hormone bse amd result in han hd been oosures such as iedical X-rays that Y bone seeking lo not merely es provided by the ancer development tses against ng bot total and id (6).
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environmental samples, nor does the govertmuet measre bone conctrations jf this element after 1982, and milk concentrations of this critical element each month in a senies of tes across the nation since 1990. TkIs, prechtly the operators of nuclear ractos only need tq meae gamma my emitting elements such as Cesium-137 that can be more easily and cheaply m ed than Strontium-90 that emits ady short range electrons th cannot penetate the Geiger counterl used for gamma rays, and which rEq more costly laboratory pwcedr for each sample.
- 22. As recently brought out in the ECCR report (6), the reason why the risk exposums due to inhaled or ingestedradioacfive chemicals is some 100 to 1000l same dose due to sha exposts is that for tie low doses given over a long per free-radicals of oxygen dominate over direct damage to the DNA and cell memb a dose-reqx e acrve ffiat rises extremely rapidly for vexy small doses and then doses, thus causing the eor made by a linear extrapolation to zer dose used to existing safety standards for permitted releases from nuclear pants.
- 23. Thus, the ECRR report states in paragraph 10 of its executive smynaty cancer epidemic is a cosequence of exposure to global atmospheric weapons 1959-63 and that more recent releases of radioisotopes to the envii operation-of the nuclear fuel cycle will result tn-significant increas other types of itf health (Emphsi added).
- 24. Thus, in the concluding paragrapt of the executive sumnmary, it says fftat committee's belief that nuclear power is a costly way of producing energ when deficits art included in the overall assessment' and that ithe envrocxnental consc radioactive discharges must be assessed in relation to the total environment, incl9 indirect effets on all living systems."(6).
low protracted imes greater than the td the damage by e es. This leads to 1fiten out at high at the present inout the period ent from the Is n eancer and itis "the human health queuce of ding both direct and
- 25. Although the most serious airborne radioactive releases so far have occured from the operation of Unit I which was a Boiling Water Reactor (13WR) pnanetly clod in 1996, studies descmibed in references (1) and (2) have found similar increases in infant moet, low birthweight and cancer around Piessurzed Water Reactors (?WR) such as Shippingport nePittsburgh and Indian Point near New York Cily. Therefore, it is to be expected that a twenty y renewal of the operating licenses for hfillstone Units 1 and 2 would further cae he advese effects on humm health and their associated cost in health care, as well as dte damage to wildlife, Iirds and fish that have been rising alarmingly in recent years.
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- 26. Tis fuilerincrease of damage to h n health and te enviroment i t onl tdue to the short-lived dioactive elemets such as lodine-131, butw also due to the long f-life af many of the radoactive cmicals rou l releadby nuclearplat such as the 28 years i takcs forthe activity of Strontium-90 to decrease by half. Thus, it is veay likely that conn e
'on of the Millstone Nuclear Plant will further increase the rates of cancer, low bihweighi, infant a ortaity and chronic disease such as hypothyroidism, diabetes, and other diseases treated to immu4 and hbomonal system damage as these elements acaumulate in the ueround water table f mnwhich wells draw their water, making it ibmssible to safely protect the public.
- 27. 'Te mexpectedly gnz risk to the life and future heat of the newbomre doses of radiation to critical organs has just been further supported by a stud o prematur births leading to underweight infants as reported in the April 28, 20(
Joumal of the American Medical Association (7). This study revealed that the vi scattered rdation to the thyroid in the neck of die mother prodced by just one during the first tree months of pregnancy, approximately 40 millirem eadh, sig the risk of premature birih and low birth weight. This in turn is nmown tD Inma well as prodrcing a greater danger of mental and physical problems fo infantsI result of recent advances in neonatal care, but at huge emotional cost to tbe fami care costs to society.
- 28. In the light of current Imowledge of the unanticipated serious advese effq of extre ely smail doses of prolonged ee raiaon eXpos-to Str" fission products as described above, it is my professional opnit lhat the Millst would need to end all radiation releases in order to meet public heath requiremei t drefore they should not be granted license renewals to continue operations twenty year renewal periodwilhout demmstrating that this objeive can be achic I hereby declare the forging to be true and acacrate to the best of my knowX and belief under penalty of perjuy.
Em8ess J.
8,2004 Dated: AuguW 8, 2004 tovery mml the incidence of 4 issue of the q sn1 dose due to Dr two denWa X-rays kificanty increased e infant moftalty as vbo survive as a ly andrising healt Uts on bumm health Utium-90 and other me 2 and 3 reators ts for sfety, and during the proposed red.
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I LIST OF REFERENCES I) Ernest J. Steniaglss, 'Secmet Fallout Low-Level Radiation from Hiroshim Island" (c w - Hill. New Yok, 1981) Avable on the website w affi
- 2) Ernest J. Sternglass, Environmental Radiation and Human Health", pp.14 of the Sixth Bckeczy Symposium on Mathematcal Statistics and Probability: EA Health", EFited by M. L. Lecam J. Neym
. Scott, Uhivezitry of Californi Los Angelm 1972.
- 3) Eiest I. SteWass "Cancer Moruqit Cges Amund MCle= Fadi pp. 174-212, "Radiation Standards anud Human Health: Proceedings of a Con Febnry 10,1978 published by the Ezvironmenal Pblicy stitute, Wangton,
- 4).Joseph J. Mhngano, "isks of Cancer And Other Diseases frx ThOpe Millstone Nudlear Hant," Agus 5, 2004, Radiation and Pubic Hea
- Project, 5). Fmesxe vs. FLP, Case Number 03-140040-C[V-COHN/LYNCHC
- 6) Pilippe P. Huel et al. "AntepaIUm Dent Radiogray and Infai Low E Journal of the American Medical Assodation, Volume 291, No.16, April 28,2
- 7)."HaEffects of Ionizing Radiaton Exposuve at Low Doses for Radiati Purposes: Recommendaions of the Europe Committee on Radiation Risk", E I with Rosalie Berte Inge Schmitz - Feuerbake, Molly Scott Cato and Alexci Y for the ECRR by 3ren Audit Pftss, Castle Cottage, Aberystmy't, SY 23iDZ, (2003) Website: www. cuadcoatorg 2003.
ctolThreeMile
- ionorg.
5-216, Proceedings I es of Pollution on Press, Berkeley and in Conrectcut",
.ssionaI Seminaro, DC.
ration Of The New York, NY.
irth Weight.,
04, pp. 1987-1993.
Proection Ried by Cbris Busby
,lokov, Published Jnited Kingdom.
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