ML051150243

Comment (26) of Nancy Burton on Behalf of Connecticut Coalition Against Millstone Millstone Nuclear Power Station/Draft Environmental Impact Statement

ML051150243
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: ML051150243 (18)

Text

C()NNECTICUT COALITION AGAINST MILLSTONE www.mothballmillstone.org March 2, 2005 Rules and Directives Branch i '1d/e Z31 Division of Administrative Services Office of Administration 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 Impact 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. Ad T 6ŽL', _

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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. Sternglass, 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 Radiological 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.

"This 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 Nan yurton Please address correspondence to:

Nancy Burton 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 5

Memor um to: Nancy Burton Date: 03/ 1/05 From: E est J. Sternglass, Ph. D.

Subject:

llstone Relicensing I have rec ntly had the opportunity to examine the levels of radioactiviy-in goat milk samples rtported by Dominium Nuclear Connecticut, Inc. in their Annual Radiological Environm ntal Operating Reports and found that highly significant concentrations of carcinogenic fission products were measured, indicating that the Millstone nuclear plant continues o represent a major health hazard to the people of the area.

Thus, in thz enclosed copy of Table 8 of the Report for the year 2001, a concentration of 55.5 picod ries per liter (PCI/L) of milk of Strontium-90 was reported for Location 22 for the sa4 le 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 ib Connecticut pooled milk at the height of nuclear weapons testing in 1963 of 23 PCY/L, as can be seen from the enclosed Figure 6-1 prepared by the Dominion Company for the period 1961 to 1993. Moreover, since the measured'value is ten times as large as thc measurement uncertainty, this is an extremely significant result, with an astronomicn.ly small chance that it is a statistical fluctuation.

To put this nto perspective, using the NRC NUREG 1.109 dose factor of 0.0172 mrem/PCI from Table A-5, a mere 2.4 PCI daily intake results in the maximum permissible dose to any organ of 15mrem per year set by NRC guidelines, 23 times the amount measured in a single liter.

Moreover, ince strontium-90 has a physical half-life of 28 years, it must have been present fort number of days that month. In fact, only 16 days at the measured concentration of 55 PCIIL are sufficient to reach the permissible dose.

As the enclosed samples of measurements show, concentrations of 13 to 14 PCl/L were found on other days, again significantly higher than the measurement uncertainty of 1-2 PCI/L.

Moreover, As 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 milk show significant concentrations of other fission products, such as Cesium-137, again significant concentrations.

The high cca'centrations of Sr-90 and other isotopes measured clearly exclude the possibility that they are due to past nuclear bomb-tests. No other sources of Sr-90.exist other than tbe fission of Uranium, so the measured values repreent releases from Millstone. j

PAGE .02, .

,:B'B>/P1/2005 21:09 4126816251 . I

.. 7.

As recen~ y shown in the 2003 report by the European Committee on Radiation Risk, numerou epidemiological and laboratory studies have shown that the risk of cancer and other disc es produced by local internal doses to critical organs frdm fission products that are in aled or ingested, have been underestimated by extrapolation from high external d ses by factors of hundreds to thousands of times. This explains why it now

- appears tl t releases from nuclear plants, often acting synergistically with other environni ntal pollutants, are a major neglected reason for the recent rise of illness and deaths boa among newborns and the elderly observed in the U.S in the last two decades,

, as also dii ussed in the ECRR report.

.,i For these i=ons, it is my professional opinion that the Millstone Nuclear Plant should not be reli ensed.

i':

Ernest J. S rnglass, Ph. D.

Professor meritus of Radiological Physics University Pfittsburgh School of Medicine Home ad ss:

University quare #2 4106 Fifth e.

Pittsburgh, A 15213

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Iv hw;l+ -6'6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFFlY AND LICENSING BOA RD In the Matter of DOMINION NUCLEAR CONNECTICUT, INC.: Docket Nos . 50-336-LR, SO-423-LR (Millstone Nuclear Power Station, Units 2 and 3)  : ASLBP No. 04-824-O1-LR DECLARATION OF ERNEST I. STERNGLASS L Ernest J. Steruglass, do hereby declare as follows:

1. I am above the age of eighteen (18) years and I believe in the obligation of an oath.

2.1 reside at 4601 Fffif Avenue in Pittsburgh, Pennsylvania, 15213.

3. submit this declaration in suppxft of Connecticut Coalitiou Against Mill3 tone ltervention in the above referenced matter.

4.1 am Pfessor Emeritus of Radiological Physics at the University of Pitt urgh School of Medicine and have written and published extensively in the awea of low-level rad ation and human health, and about the adverse effects of radioactive emions from the Millstme Nuclear Power Station in particular.

5. 1 am the author of the book "Secret Fallout Low-Level Radiation from Hin chima to Thre-Mile Island published by McGraw-Hill in 1981, of the review article !nvirotu etal Radiation and Human Health" published by the inivcrsity of California Prss in 1972, and the uicle "Cancer Mortality Changes Around Nuclear Facilities in Connecticut" published in "Radia dto Standards and Human Health: Pnceedings of a Congressional SeminarFebruavy 10, 1978, by I be Environmental Policy Institute in Washington DC. The facts and statements contained in these pt blications art incororated by reference herein as references 1, 2 and 3 respecively.

6.1 have published a serks of papers on 6*ects of low-level environmental radiation on human health and developmf produced by nuclew weapons tests and ractor Ml uses for tiq1ast ISZ9189Zlv :TZ 60'7 0V8IVEI0 TE 39Vd

I forty years, and have testified on this subject at hearings held by the U.S. ConEr ess, the National Academy of Sciences, State Legislatres and U.S. Government Regulatory Age rvies as an expert on this subject.

7. It is my professional opinio that the radioactive releases from the Millstoi e Nuclear Power Station since its startup in 1970 have caused and will continue to cause excess t dfant mortality, low birthweight, leukemia and cancer as well as increased rates of both chronic and i fectious diseases in the towns around Millstone as well as in New London County and Conneticut ts a whole,

8. According to the NRC publication "Radioactive Materials Released Fmm: Tuclear Power Plants' (NUREG ICR -2907), by 1987 Millstone had released a total of 32 Cur es of radioactive Iodine and Particulates into the air which include the highly carcinogenic StrorK im-90 and Iodine

-13 1, together with 6.7 million Curies of Total Fission and Activation gases s i as Xenon and Krypton, and the highest liquid releases of Mixed Fssion and Activation ts of any nulear plant in the United States, namely 581 Curies or 581 trillion picoCuries, the uni of concern in milk and drinldng water,

9. In a single year, 1975, Millstone released a record high of 9.99 Curies of Ddine and Pariculatesinto the air, more than twiceas high as tbe4 Curiesreleasedshordy after startup in 1971, together with 29.7 million Curies of Total Fission and Activation Gases, d l99 Curies of liquid Mxed Fission and Activation Products into Long Island Sound, also are rd for all U.S.

nuclear re-actm

10. Between startup of Millstone in 1970 and 1975, as shown in the 1978 tone report (3)!

cancer mortality rose 58% in Waterford where the reactor is located, 44% in Ne London Smiles to the nouth-east, 27% in New Haven 30 miles to the west, 12% for the State of ceut as a whole, 8% in nearby Rhode Island, 7% in Massachusetts and 1% in New Hamnr re, while it actually declined by 6% in the most distant New England state, Maine, followiq the pattern of Strontium-90 in the milk shown in the same report.

11. As shown in Table 9 of reference (3), while the Strontium-90 concentratic in the mik declined for the U.S. as a whole between 1970 and 1975 from 8 picoCuries per I terto only 3 pCil, it rose from 9.8 in 1970 to a high of 15.8 in 1973 and 14.8 in 1974 near theMil tone Nuclear Plant, remaining at 10.7 by 1975. This is far in excess of the U.S. average of 3 pCi/l, r fling out any significant contribution to the local nilk fiom bamb test fallout by France and Ch na that continued until 1980.

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12. As shown in Table 10 of rHference (3) the calculated yearly radiation dos to bone of a child due to the excess Strontium-90 within 1015 miles of the plant in excess of the: early dose for the U.S. rose from 33 millirem per year in the first full year of operation to 204 mr yrby 1974, nearly three limes the normal background level of 70 rnremlynT in Connecticut.

13. These doses due to Strontium-90 alone may be compared with the 15 mr to any organ toyr permitted under current NRC regulations, the 2 mrem produced to bone marmo in a typical chest X-ray of a child, and the 80 miem/yr to a developing fetus found to produce a ling of the rat of childhood leukemia in the studies of Dr. Alice Stewart cited in Reference 7 ol reference (3) for exposure in the mothers womb to X-rays in the first three months of pcregnanc

14. These considerations, later supported by the more recent studies of Stron Xum-90 measured in baby teeth together with effects on cancer incidence and infant mortality as repo] by Margano submitted in the present case and referred to here as reference (4) provide over" heming evidence for the existence of a causal relationship between the abnormlly high levels of St l num-90 in the milk and the pattern of cancer changes at various distances from the Millstone plant

15. The existence of a direct causal relationship between Strmoium-90 rel id from nuclear reactors and an inc ed rsk of cancer is very strongly suported by the fin

• described by Mangano (4) tait baby teeth of children diagnosed with cancer have close to able the concentration of Strontium-90 than children born the sane year and in the same area. This finding has ledt a lawsuit having ben filed in Florida against the Florida Power and igh company by the family of a child with a very high Struntium-90 tooth concentration seeing on pensation, a suit which a fedaljudge nrled to be of sufficient merit to go to trial in 200S, desi eefforts of the defendant to have it dismissed (5).

16. As pointed out in reference (3), this conclusion is still further supported v the fact that the types of cancer that rose most strongly in the Connecticut area near the Mlston Nuclear Plant are exactly those that have been found to be most sensitive to radiation in caier s lies by national and international standard setting organizations, namely those that increased the modt by 1975, such as respiratory cancers (37%), breast cancer (12%), and pancreatic cancer (32%).

17. Likewise, further support for a causal relationship of nuclear plant rel s and adverse health effects is provided by the fact cited by Mancuso et al.(s) cited in reference (1) kt cancer deaths showed a much greater rise in women than in men, namely 17% for white wo m and only 11% for

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white males. This same diffrence between males and females was found by M ancuso and his co-investigators for atomic workers at the Hanford Nuclear Plants exposed to low doses of both internal exposures to critical organs due to inhaled and ingested radioactive elen rnlssimilar to those released by Millstone over a period of years, together with protrated external e]:posiurs from gamma rays produced by fission products accumulated on the ground, rather th m to veiy short X-ray exposures used in diagnostic procedures.

18. A renewed rise in infant mortality in the six towns nearest Millstone took place after a sharp decline by 18% when all thSee units had been shut down for most of 1996-97 as described in Table 9 of the 2004 report by Mangano (4), with a smaller decline of 3.1% in 1998-99 relative to 1994-95, followed by a rise of 8.8% in 2000-01. This is very strong evidence indicating t even the much smaller releases from the two remaining PWR type of reactors continue to adver rely affect the health of the newbom so that there can be no safe operation of any existing type of nuc ar plant for the developing children on whom the future of our nation depends.

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19. The much greater risk lo human health from radioactive gases and particli that are inhaled or ingested and concentrate in certain critical organs such as the bone maWw or harmme priducing glands such as the pituitary gland targeted by the highly radioactive daughter duct of Strontium-90, the element Yttrium-90 that has different chemical properties and leaves the >one to concentrate in soft tisses. This resultsin very high local doses to both the bone marrow an Ithe critical hormone producing glands over long periods of time that greatly exceed the whole-body ose and result in cancer and other adverse effects on health hundreds to thousands of times great r than had been expected by a linear extrapolation to low doses of the risk from short external e posures such as received by the survivors of Hiroshima and Nagasaki or individuals exposed to medical X-rays that 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 Strontiumn-90 and ot] ker bone seeking radioactive chemicals routinely released by nuclear plants that resemble Calcium do not merely increase the risk of bone cancer or leukemia, but they weaken the immune defer ses provided by the white cells of the blood that originate in the bone marrwiv. As a result the rate of cancer development all over the body normally held in check by white cells is increased, and the deft uses against infectious diseases such as influnza, pneumonia and AIDS are lowered, inch ing both total and infant motality due to all causes combined as discussed in references (1X2X3) ind (6).

21. Unfortunatly for the protection of human health, the operAtos of nucl rplants such as Millstone are no longer reqired to measure Strintum-90 in the milk, the sil, ie water and other VE 39Vd ITz9189Zlt 60:Tzl OOZ/TG/EO

envimmnental samples, nor does the governmcni measure bone concentainm f this element after 1982, and milk concentrations of this critical element each month in a series of cities across the nation since 1990. Thus. presently the operators of nuclearreactors only need t meae gamma ray emitting elements such as Cesium- 137 that can be more easily and cheaply nased than Strontium-90 that emits only short range electrons that cannot penetrate the Gciger counter used for gamma rays, and which requires more costly laboratory ptocedures for each sample.

22. As recently brought out in the ECCR report (6), the reason why the risk4c low protracted exposures due to inhaled or ingested radioactive chemicals is some 100 to 1000 Iimes greater than the same dose due to short exposres istat for the low doses given over a long edamage eod by free-radicals of oxygen dominate over direct damage to the DNA and cell menb es. This leads to a dose-response curve that rises extremely rapidly for very small doses and then flattens out at high doses, thus causing the error made by a linear extrapolation to zero dose used to establish the existing safety standards for permitted releases from nuclear plants.

23. Thus, the ECRR report states in paragraph 10 of its executive summary That the present cancer epidemic is a consequence of exposure to global almospheric weapons ftlout in the period 1959-63 and that more recent releases of radioisotopes to the enviro ment from the operation of the nuclear fuel cycle will result in significant increase s In cancer and other types of ill health (Emphasis added).

24. Thus, in the concluding parag l of the executive summary, it says that t is "e committee's belief that nuclear power is a costly way of producing energy when ua health deficits are included in the overall assessment" and that The environental cons iuences of radioactive discharges must be assessed in relation to the total environment, including both direct and indirect effects on all living systems."(6).

25. Although the most serious airborne radioactive releases so far have oc d from the operation of Unit I which was a Boiling Water Reactor (BWR) pemmanently do~d in 1996, studies described in references (1) and (2) have found similar increases in infant mortaliilow birthweight and cancer aroind Pressurized Water Reactors (PWR) such as Shippingport neaf Pittsburgh and Indian Point near New York City. Therefore, it is to be expected that a twenty y~r renewal of the operating licenses for Millston Units 1 and 2 would further increase the adve effects on human heal& and their associatcd cost in health care, as well as the damage to wildlifebds and fish that have been rising alarmingly in recent years.

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I

26. This further incrase of damge to human health and the environment is lot only dae to the short-lived radioactive elements such as Iodine-131, but also due to the long hal f-life of many of the radioactive chericals routinely releed by nruclear plants such as the 28 years i: takes for the activity of Strontium-90 to decrease by half. Thus, it is very likely that continued operal on of the MIllstone Nuclear Plant will further increase the rates of cancer, low biWiweight, infant ortality and chronic diseases such as hypothyroidism, diabetes, and other diseases related to and honmonal system dmage as these elements acctuulate in the underground water tble f m which wells draw their water, waking it impossible to safely protect the public.

27. The unexpectedly great risk to the life and future health of the newbomd ue to very small doses of radiation to critical organs has just been fuither supported by a study "the incidence of premature births leading to underweight infants as reported in the April 28, 2 4 issue of the Journal of the American Medical Association (7). This study revealed that the v xy snall dome due to scattered radiation to the thyrod in the neck of the mother prolced by just one pr two dental X-rays during the first three months of pregnancy, approximately 40 millirem each, s tiicantly increased the risk of premature birth and low birth weight This in turn is known t inC infant mortality as well as producing a greater danger of mental and physical problems fr infants rho survive as a result of recent advances in neonatal care, but at huge emotional cost to the fami andrising health care costs to society.

28. In the light of current knowledge of the unanticipated serious advers eff rtsa on humn health of extremely small doses of prolonged enviromental radiation exposures to Strcintium-.9 and other fission products as described above, it is my professional opinion the Mlllst ;e 2 and 3 reacors would need to end all radiatimn releases in order to meet public health roquiremeerts for safety, and that therefore tiey should not be granted license renewals to continue operations pduring the pruposed ntenty year renewal periodwithout demonstrating that this objective can be achie red.

I hereby declare the fortgoing to be true and accurate to the best of my knowl e, infonnation and belief under penalty of perjury.

Ernest J. S#Ugass ff~

Dated: August 8, 2004 60:TIZ G0Z/IO/EO 96 BSZ9T896Td 39Vd

LIST OF REFERENCES

1) Ernest 3. Stemnglass. "Secret Fallout: Low-Level Radiation from Hiroshli I to Three Mile Island" (McGaw - Hill, New York, 1981) Available on the website www.radi lion.org.

2) Ernest J. Stemglass, "Environmental Radiation and Human Health", pp.1 15-216, Proceedings of the Sixth Berkeley Symposium on Mathematical Statistics and Probability: El [ects of Pollution on Health', Edited by M. L. Lecam, J. Neyman El. Scott, University of California Press, Berkeley and Los Angeles, 1972.

3) Ernest J. Stenglass. "Cancer Mortality Changes Around Nuclear Facilt s in Connecticut",

pp. 174-212, "Radiation Standards andHuman Health: Proceedings of a Congr nssional Seminar",

Febnrary 10, 1978 published by the Environmental Policy Istitute, Washington, DC.

4) . Joseph J. Mangano,"Risks of Cancer And Other Diseases From The Opc ration Of The Mlllstone Nuclear Pant" August 5, 2004, Radiation and Public Health Project, New York, NY.

5). Fmnes e vs. FLP, Case Number 03-140 -C V-COHN[LYNCHC

6) Philippe P. Huel et al. "Antepartum Dental Radiography and Infant Low Eirth Weight",

Journal of the Amenican Medical Association, Volume 291, No.16, April 28,24)04, pp. 1987-1993.

7) . "Heah Effects of Ionizing Radiation Exposum at Low Doses for Radiatii nPRmection Purposes: Rccommendations of the European Committee on Radiation Risk", E iited by Chris Busby with Rosalie Bectell, Inge Schmitz - Feuerhake, Molly Scott Cato and Alexci Y2blokov, Published for the ECRR by Green Audit Press, Castle Cottage, Aberystwyth, SY 23iDZ,1 Jnited Kingdot.

(2003) Website: www. curadcoinorg 2003.

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