ML082391039

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Declaration of Philip R. Mahowald for Prairie Island Indian Community with Regard to Prairie Island, Units 1 and 2, License Renewal Application
ML082391039
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 08/18/2008
From: Mahowald P
Prairie Island Indian Community
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-282-LR, 50-306-LR, License Renewal, RAS 1052
Download: ML082391039 (34)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In re: License Renewal Application Docket Nos. 50-282 and 50-306 Submitted by Nuclear Management Company, LLC PINGP, Units 1 and 2 DECLARATION OF PHILIP R. MAHOWALD

1.

My name is Philip R. Mahowald. I am General Counsel for the Prairie Island Indian Community in the State of Minnesota.

2.

Attached to this Declaration as Exhibit A is a map which shows the lands held in trust by the United States for the benefit of the Prairie Island Indian Community

3.

Attached to this Declaration as Exhibit B is a true and correct copy of Digging in at Prairie Island, which upon my information and belief, was published in the NSP News on or about September 1967.

4.

Attached to this Declaration as Exhibit C is a true and correct copy of Prairie Island:

From antiquity to atoms, a publication produced by Northern States Power Company.

5.

Attached to this Declaration as Exhibit D is a true and correct copy of a July 4, 2008 letter from Ronald C. Schirmer, Ph.D. to Ron Johnson and Mike Wadley.

6.

Attached to this Declaration as Exhibit E is a true and correct copy of Childhood Cancer in the Vicinity of Nuclear Power Plants: The 2007 KiKK Study - IPPNW Physicians Issue Warning: Young children develop cancer more frequently when they live near nuclear power plants (NPP). It has to be assumed that radioactive emissions from NPP stacks are indeed not as harmless as previously believed. Now it is time to act, information published by IPPNW/Ulm Physicians Initiative - January 2008.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 18th day of August, 2008, at Welch, Minnesota.

Signed (electronically) by Philip R. Mahowald Philip R. Mahowald Prairie Island Indian Community State of Minnesota County of Goodhue

Prairie island Indian Community Land in Trust = Approximatly 1,986 acres Legend Railroad Pierce RR

-US Highway State Highway CSAH & County Roads Municipal Roads Prairie Island Parcel Boundaries vv~r 0.45 0.9 N

1.8 Red Wi

Dr. lohnson looks at a map o~

Prairie Island while the students screen soil i~ search o~ small al~ffacts, University o~ Minnesota archaeology students uncover an ancient ~repit, around which an American Indian [amily once sat to cook its meals.

[~ S ~ is helping to uncover the past

]?or the future at the site ~ the largest generating plant. The 1.1 clear generating station to be built 0n near Red Wing is in an area rich in.

treasures. NSP is-underwriting a salVa.

sponsored by the Minnesota Historical S effort to find any valuable artifacts construction o~ the power plant.

Farming Indians who lived on Prairie 2,000 years ago. left behind a weaith of about their culture, according to Dr.

Minnesota state archaeologist and of anthropology at tl~e University of is directing-the Prairie Island project.

The recent archaeological salvage site has produced evidence o£ two ~naj~

Indian sites, according to Dr..

site so far consists.of a series of earth

1ohnson, right, and.

University o[ Minnesota a ~ar hand~ ~

Indians who ~arraed Prairie years ago.

Dave Wystuen charts a find while Dr. lohnson supervises the work oi other students.

p AI RI E I.SLAND says were probably constructed dur-Woodland period, between 500 B.C.

The second major site is that o~ a large occupied between-1200 and 1500 Indians..

mohnds are located on and adjacent to.

location.o{ the cooling towers to be built Excavation o{ these mounds will be done -

.!all of this year or in the spring o{ 1968 o£ the village site produced a large stone tools and pottery ~agments as well o£ large {hod storage pits. The site dates tradition called..Mississippian by and.is one o{ the £ew such sites in Min-r.emain in,. an un~bed.condition, been cultivated. Excavation of-the village site is planned ~or later in 1968 is not in.the. area o~ initial construction..

generating plant planned by NSP.

Dr. ~ohnson.is hopeful that in his studies o~ Prairie island bewill someday find the remains.of a trading post built.on the island in 1696 by Pierre Le Sue.ur, the French explorer. The area is rich in general arch-aeological value, with more than 2,000. prehistoric.

burial mounds recorded within a five.mile radius o~

the junction o~ the Cannon-and Mississippi.rivers.

Historic contacts between Europeans and American Indians took place near Prairie Island, and it was near there that Father Hennepin first met the Mdewakanton Sioux.

Dr.. Johnson has speeded parts of the study by bor-:

- rowing a trenching machine and operator from. NSP.

The. machine is used to locate large concentrations of artifacts, at whieh time the careful job of uricovering treasures is taken over by the University of Minnesota arehaeoiogy students working With Dr. Johnson. The treneher is "a. bit rough," but it.saves time in locating a worthwhile digging site:

0

o
ontents om antiquity to atoms uclear power Prairie Island plant lan on top at the AEC

,igging into,the past pecifications

- PAG E 3

16 16 18 SUBSTATION

.POWER HOUSE INTAI~ E.CANAL Past, present, and future are represented in this north-looking aerial photo of NSPs grounds at Prairie Island.

The company is sponsoring excavation of ancient Indian sites, in foreground, while not far away NSP is building a modern atomic power plant.

Location of the plants main features are outlined in white,

.li INDIAN BURIAL MOUNDS AREA DISCHARGE CANAL 4, COOLING TOWERS SITE OF THE INDIAN VILLAGE

From antiqu.it,, to ato.ms S

INCE EARTH BEGAN, powerful forces have.

roamed the site where Northern States Power Company is building another nuclear elec-tric-generating plant.

The location is Prairie Island, now an eight-by-two mile peninsula on-the Mississippi River 28 miles.

southeast of the Twin Cities and six miles northwest of Red Wing, Minn.

NSP will begin operating a 545,000-kilowatt plant at Monticello, Minn., in 1970. Construction on the nuclear plant at Prairie Island began in 1968,.

with one nuclear reactor-of 550,000 kilowatts sched- "

uled to start operation in1972 andthe second of.

550,000. kilowatts in 1974 Its part of a world-wide trend toward peaceful harnessing of the atom. In the U.So alone, 17 ato.mic.

3ower plants were operating, with 16 under con-struction, and some 50 more plants being designed as of mid-1968, later Indians and for European explorersl The French-The. story Of power, at Prairie Island ranges from man Pierre LeSueur visited the grassy island about glowing lava five billion years ago to present-day.. 1696and named it"prair.ie" ("bald")because he saw sandy soil. Wandering Indian-hunters came to the sceriic wooded bluffs and flat islands of the upper Mississippi RiverValley. after the last glaciers with-drew some.11,000 years ago. By about 800 A.D. a group lived.part of each year in a small hunting and fishing settlement on Prairie Island.

From 1400-1500 A.D. a different, gro.up of Indians lived year around on Prairie Island.in a small farming village.

Both of the Indian sites at Prairie island are on NSPs560-acreplant grounds. The company is financing, a. major excavation by the state archaeol-ogist,.Dr. Elden Johnson of the University of Minne-sota. See page 16.

Prairie Island was a natural stopping-place for relatively few trees.

In 1886 some.of the Indians who had been or-dered to move west afteran uprising during the Civil War were allowed back to Prairie Island from.their Nebraska reservation. Today, descendants of these Sioux are among the farmers on Prairie Island.

Now NSP plans the most exciting change at Prairie Island since man first left. footprints in its sandyshore.

More power, benefitting more people, will be created by NSP than any. Indian medicine men or French

.. voyageurs dreamed about b~: an evening;s smoky fire.

Yet outside NSPs plant, life will go on undis-turbed for the almost two million residents within

.50 miles radius. The company is making sure there can be no. danger even to the plants immediate

neighbors, who raise dairy and beef cattle,soybeans, -

corn, and cannery crops. Commercial carp fishing will continue. So will sport fishing for crappies, bass, walleye, and other fish, and hunting for ducks,, pheas-ant, and deer. Pleasure boating and commercial shipping, which use U.S. lock and. dam No, 3 about..

one mi!e downstream from the site will be unaffected by the plants operation.

High-voltage. transmission linesof NSPand other regional utility systems areconnected into the 10,000 mile MAPP network to provide improved reliability and economic benefits.

NSPs greatest c~ncentration of customers is served by a network of generating plants connected by 345,000-volt transmission lines.

- - Infact, NSP isdesigningthe atomic power plant to be safer, nearer, cleaner, and less trouble for its neighbors than most any other kind oflarge indus-trial.plant thatmight locate in a rural place. And the company has considerable atomic-power eXperience.

NSP customers double their demand for electricity every 10.years. Thats a big order. The Prairie Island reactors are ideally located to tie into new 345,000-volt lines that circle th~ ~rea of largest demand on N S Ps system.

The plant also will be co.nnected with lines to other power suppliers in Chicago, St. Louis, and Kansas City.. ConstructiOn of those lines is being co-ordinated by NSP and 53 other members of a re-gional power organization called the Mid-Continent Area Power Planners (MAPP).

N u,c" I.e ar p o.w..e r A

LARGE POWER PLANTS are much alike in the way they generate electricity. What sets them apart is the fuel or mechanical force used to operate the plant generatorl Nuclear fue! produces an astonishing 100,000 times as much energy as the same weight of coall When. compared with gas or oil, the nuclear advan-tag.e is even. better.

Inside a special furnace known as a nuclear re-actor, useful heat is created.when certain types of uranium atoms are broken into smaller atoms.

These uranium, atoms also.release radiation" par-ticles such as electrons, protons and neutrons,, and Gamma rays which are similar to radio, waves.

The flying neutrons trigger the splitting of.more uranium atoms in a chain reaction. Inserting or.with-drawing materials thatabsorb neutrons provides control of the heat production by regulating the number of splittings.

Radiation cannot be detected by human senses, but is easily found with ordinary photographic film or instruments such as a Ge.iger counter.

Shielding stops direct radiation near its source, so numerous.special shields will be used at the Prairie Island plant. The remaining radioactivity will be con-trolled in the plants solid, liquid, and gaswaste-OIL OR GAS OR BOILER COAL FUEL, REACTOR -

ST, EAM GENERATOR DAM TURBINE-GENERATOR TURBINE-GENERATOR TURBINE GENERATOR TRANSFORMER -TRANSMISSION

-LINES TRANSFORMER TRANSMISSION LINES- "

TRA.NSFORMER TRANSMISSION LINES t

handling systems.by using one or more of the fol-lowing methods" Filtering.

Removing radioactive minera/so Distillation to reduce the voiu-me of stored fiquid.

Diluting the remaining liquid or gas. -

Storage for radioactivity to subside.

Removal to distant sites for permanent disposal -

When at the weakened levels approved by gov-

- ernment agencies, the liquid radioactive materials will be released for dilution in the discharge canal downstream from the pipes which release condenser-cooling water. Radioactive gas, when at safe con-centrations, will.be released from vents at the highest point of the plant for dilution in the atmosphere.

Radioactive wastes from the plant will be moni-tored carefully by NSP to be certain thelevels remain within Atomic Energy Commission (AEC) limits.

Monitoring also will be done by government agen-cies and scientists from independent organizations.

Experts are hired by NSPto make sure heated discharges from the companys plants are not harming aquatic life.

Testing the St. croix River are Roscoe Co!lingsworth, left, consultant on fixed.

algae;.Paul Lee, center,.

NSP engineering associate at the Allen S, King plant which is visible in back-ground; and Dr. Alan Brook, expert on free-floating algae, from the University of Minnesota, R

ADIATION has existed since the beginning of time and its strength varies-from place.to place. So the natural level of radiation around the Prairie island plant site.will be determined at least one year prior to fuelloading. To assure safety after start-up, total radiation strength and the most important sources will be monitored regularly atthe follOwing locations River upstream and downstream from the plant.

Mud from the bottom of the discharge canal and river..

Fish and other life.in the river upstream and downstream from the plant.

Air, prec~pitation,, and vegetation including crops up to several miles from the plant.

Underground water supplies up.to several-miles from the plant. -

Milk from dairy herds up to several miles from the plant.

The two reactors at Prairie Island will be Con-.

trolled by NSP operators aided by sophisticated con-trois and computers. The AEC requires that. nuclear power-plant supervisors and technicians must be thoroughly trained and must pass.written, oral, and operating tests given by the AEC..

Under watchful eyes of.theAEC and state agen-cies, elaborate safeguards are taken at every atomic power plant to keep radioactive and heated dis-charges within safe limits. Containment of atomic explosion, however, is not a problem because the

conditions needed for an A-bomb are not.present.

Congress has made the AEC responsible for de-veloping and safeguarding peaceful uses of atomic energy. These are the steps taken for the Prairie.

Island plant to meet AEC requirements:

Experts in nuclear science who. are members of the AEC Division of Reactor Licensing made a care-ful review of NSPs plant description and preliminary safety analysis report.. When approval was gained, NSPs application went to the Advisory Committee on Reactor Safeguards for review. That is an inde, pendent group of men recognized for national stand-ing in scientific and engineering specialties. When they were :satisfied, a three-mar~ Atomic Safety and Licensing Board, including two experts in nuclear technology,, conducted a. pu.blic heatingat which NSP and the contractors were questioned. This.was the final step before issuance of a provisional permit for construction "

At. least a year before fuel loading, the company wil! submit.its final, description, safety analysis re-port, and technical Specifications. For a second time, NSPs plans wil!. be reviewed by experts of the AEC Division of Reactor Licensing and the Advisory. Com-mittee. When approved,"an operating license will be

- issued to authorize loading of the reactor with fuel.

During both construction and..., operation, the AEC Division of Compliance makes inspections, to be sure AEC standards are being met.

Permits.also must be obtained from the Minnesota Conservation Department to withdraw river water for cooling,-from the Minnesota Pollution Control Agency (MPCA) to-discharge the heated water into the river, and from both the Conservation Department and the District Corps of Engineers to build intake and dis-charge structures. The Minnesota Health Department must. approve" the power companys plans for mon-itoring -radiation levels in the environment before and during plant operation...

Other agencies consulted by the company, are the US. Public Health Service, U.S. Fish and Wildlife Service, and the appropriate County Board Of Com-missioners.

~~F~

is. making sure that heated water discharged into the Mis-sissippi River from thePrairie Island plant will.meetS. Minnesota Pollution Control Agency limits. The company will conduct river-life studies before and after the plant is placed in service to assure the agency that no harmful changes take place. Studies of this type are being conducted for NSPS King and Monticello plants..

Experience with the heated discharges from exist-ing power plants--nuclear and otherwise--.shows

- that most of the heat goes. into the air. The rest dis-

.sipates.into.surrounding water until the discharge cools enough to begin mixing with the other water layers.

One point about heated discharge water, some-times leads to confusion. It should be understobd.

that control of heated water from the condenser has nothing whatever to do with the control of radio-active liquid wastesoPositive control is achieved by keeping these, liquids in separate pipes, as shown on page 13.

Condenser coolant is comlSosed of water taken from the river, by means of the intake canal. Large objects are. screened from the water. Then the water is pumped through tubes in the condenser to absorb heat.from.steam outside t.~"e.tubes. The Steam is re-duced to water and returned to the steam generator.

Condenser-cooling water contains a small amount of natural radioactivity When it comes from the river, In its swift journey through the plant, the water:~,be-

.comes heated but gains no more radiation.

Normally, steam.in the condenseris not radioac-tive. But even if it should become radioactive tem-porari.ly, there is no chance this radiation could escape into the discharge.canal and. river. The reason is that the river water in the condenser is under, at-mospheric pressure of about 14 pounds per square inc.h while.steam in. the. condenser is in a partial vacuum condi.tio.n.-No steam could escape in Case of an internal condenser leak because the river water would be sucked into the steam lines. This untreated water would corrode equipment. So instruments are installed to detect such leaks and signal for imme.-

diate repairs.

After absorbing heat in the condenser, the cooling water is piped to booster pumps and then through one of two paths" If the temperature is.already within limits, the cooling water may go directly into the discharge canal If the temperature is above the limits, some or all of the water may pass through cooling towers before going to the discharge canal Cooling towers are long, tall frame-works of panels that resist Corrosion. The water is allowed to.drop down the panels so air can remove heat by the familiar process of evaporation.

STEAM LINES ~,..

OTHER SUPPORT EQUIPMENT ADMINISTRATION STEAM LINES OTHER SUPPORT EQUIPMENT

FUEL consists of 120,000 pounds of.

uranium-dioxide-shaped into small -

pellets having a ceramic appearance.

RODS of zircaloy metal, welded shut at top and bottom.

to contain pellets in end-to-end position, are held in.parallel positions.

ASS EM B LY of rods and pellets allows primary coolant to flow smoothly around the rods.

Reactor features.,.,

and ra-di.ati.on barriers ATOMIC reactions are controlled by absorbing free neutrons with rods of silver-indium-cadmium

- metal within the core, and

.by injecting absorbent liquid boron into the primary coolant.

o.

COREof reactor, seen from above.

Assemblies are moved toward center at-annual refuelings, with newest identified by dark blue squares. Oldest in light blue are removed for reprocessing.

ONTROL rods are housed in eel tubing and placed inside 3 of a reactors 121 fuel

~semblies. The adjustable

)ntrol rods replace-16 of

~e 196 stationary fuel rods these assemblies.

Many barriers sto.p.

direct radiation The most important are."

CORE containing fuel pellets, zircal.oy tubing, silver-indium-cadmium rods,, and liquid boron.., all absorb radiation REACTOR.VESSEL of steel SUPPORTS -

of concrete CONTAI.N MENT VESSEL of steel SHIELD BUILDING of concrete 11

ICOOLANT CIRCUITS SEE SCHEMA TIC TWO PIPE loops which meet in.

reactor vessel carry primary coolant of treated water. ~

PRESSURIZER in one loop maintains pressure Of 2,23.5 pounds per square, inch so primary coolant remains water despite. 560° F heat.

- COOLANT PUMP of 6,000 horsepower in-each loop moves primary coolant at almost 15. feet per second through reactor core.

STEAM GENERATORS.

STEAM GENERATOR in each loop allows heat Of primary coolant to boil secondary coolant of treated water that flows outside primary coolant tubes.

COOLANT PUMPS TURBINE-GENERATOR shaft is turned 1,800 times per minute by the resulting secondary coolant steam that is under 720 pounds per square inch pressure and 510 ° F heat, COND.ENSER changes.secondary coolant steam to water, which is then pumped back to steam generators..-

TURBINE GENERATOR co.NDENSER...

-COOLING TOWER -

RADIOACTIVE LIQUID WASTE COLLECTION

& TR EATM ENT MONITORING &

CONTROLLED -

RELEASE COOLING.TOWER SCREENHOUSE screens river water ~

from intake canal. In condenser this water takes heat from secondary-coolant steam.outside condenser tubes.

DISCHARGE CANAL and river usually receive the water.

COOLING TOWERS at times supply evaporative cooling of some water, which then goes to the discharge canal.

NEW FUEL HANDLING Fuel installed-in assemblies arrives at plant by railroad for storage in RACKS. During refueling, assemblies are transferred through water of spent fuel pool and TRANSFER TUBE...

SPENT FUE.L HANDEING REACTOR CAVITY is flooded for refueling because water is effective radiation shield that.can be seen.through. REACTOR VESSEL TOP is.

removed, new. fuel assemblies installed in core, spent, fuel assemblies removed via.tube to underwater racks in SPENT FUEL POOL where heat and radioactivity can "cool" to safe levels. Later, spent fuel is shipped in special casks to private reprocessing companies.

Fuel and waste h.andling.f GAS WASTE HANDLING "

Radioactive gas mostly is krypton and xenoa in the primary coolant system. The GAS is removed and piped to tanks for storage until radioactivity "cools" to govern-ment standards. Then it is released in controlled amounts through VENTS atop each reactor building.

Air in CONTAINMENT SPACE usually is not radioactive but is monitored-anyway, filtered if necessary, and released from vents to dilute in atmosphere in controlled amounts that meet government standards.

LIQUID AND SOLID WASTE HANDLING Liquid radioactive-waste may come from plant laundry, shower, handwashing, lab-..

oratory,.equipment drains, leakage (every drip is saved), decontamination of equip-ment, filtering, and chemical treatment of the coolant water. Some LIQUID is held "

up in tanksfor treatment and monitoring until it meets government standards,.

then is diluted in theriver in controlled amounts. Ra~lioactive SOLIDS are shipped out of state in special drums for perma-...

nent disposal.

Dr. Glenn Seaborg "Man. on top at the A.EC T

HE CHAIRMAN of the Atomic Energy - -.the. public outside of AEC plant areas.

Commission is an atomic scientist who has shared in the discovery of.inside AEC-contractor plants has been

-nine elements. He is Dr. Glenn Seaborg, winner of the Nobel prize in :chemistry, the Enrico Fermi Award, and 26 honor-ary degrees.

"In more than 20 years of operating reactors of various types," says Dr. Sea-borg, "there has not been.a single acci-dent that has caused any known injury to The safety record of personnel working phenomenally-good,"

in fact,- they are safer than industry in general, Dr. Seaborg points out.

The hard rules of the AEC in protecting the public from dangerous radiation levels take two major paths. "First, extensive safeguards are provided to prevent acci-dents," says Dr. Seaborg. "Secondly, all reactors are provided with substantial safeguards to.minimize the consequences of accidents in case these precautions should somehow fail."

DeClares Dr. Seaborg, "Perh.aps i can best sUmmarize my feelings about safety by saying that I would not fear havingmy family residence within the vicinity of a modern.nuclear power reactor built and operated under AEC regulations and

-controls."

1l Digg,ng. into the..past..

N p, S °ne-rich ground for the Min-nesota state archaeologist, Dr.

.Elden Johnson of the University of Minnesota,whose excavation of the site is sponsored by NSP.

Dr. Johnson directed a thorough survey of-the

.entire area in summer 1967, and found nothing sig-

.:nificant where the plantwill rise.But atthe south edge of the grounds, his team discovered. 10 certain -

and six probable Indian burial mounds, most of which have been worn flat by 80 years of agriculture. They also found signs.of an Indian village some 1,000 feet by 400 feet in oval shape. See page 2.

"These mounds were censtr.ucted sometime around 800 A.D.," Dr. Johnson says. "Prairie Island is im-portant because we know relatively little about Indian life during this period insouthern Minnesota and nearby WiscOnsin," he says. Pottery and. other objects placed in.the graves are.important.goals for Dr. Johnson.

"A different g!oup of Indians lived in the village between 1400 and 1500 A.D,," he says.."Because the site has been pasture, it is the only undisturbed village of this age in the region," Dr. Johnson says.

The style and arrangement of housing, and the village population, are other important goals.

The Prairie Island area was important tO Indians-because.it provided them.with meat and clothing, fish, birds, wild rice, tobacco, rock and bone for tools and smoking pipes, and clay for pottery. Wood furnished building materials, fuel, and tools.. Five major rivers and countless streams within 50 miles

- radius made Prairie Island a.transportation gateway..

THE MOUND Bi~ILDERS..

"Mound builders livedperiodically at Prairie Island in a srnall group,, says the archaeologist. "~hey ranged over 200 miles to southwestern Minneso;ta on summerbuffalo hunts, and often commuted noith 50 miles to a fishing and hunting camp near Marine-on-the-St Croix." The hunters and fishermen of Prairie island harvested only wild rice.and smoking tobacco.

The men chipped spear points, axe. heads, hide scrapers, and other tools out of local stone or animal 16

bones. Handles were wood.. Women made pottery without benefit of a potters Wh6.el,. Their cooking

. ;i~-~,

urns of local clay had fabric-impre.ssed ornamental marks on the outside, and pointed bottoms which were set in thefirewood when cooking.

But the most distinctive feature of these Indians was burial under large..circular mounds of earth.

Some mounds contained one body, a few had many successive burials. Burial mounds apparently were a true invention by Indians_ of the Ohio-Mississippi River valleys. Today, few undisturbed mounds re-main for study by archaeologists...

"The fate of Prairie Islands mound builders is a mystery," says Dr. Johnson.

THE VILLAGERS.

"While earlier Indian ways of life reached Minnesota by passage of ideas from group to group, a new way of life arrived.about 1,000 A.D. by migration Of col-onists from the south," says Dr. Johnson.

They first appeared in Minnesota near the mouth ofthe.Cannon River. That is some four miles south The Minnesota State ArChaeologiSt, Dr, Elden Johnson, supervises his excavating crew in Careful preliminary mapping of ancient Prairie Island sites. In the NSP-sponsored study, Johnson hopes to shed new light on village dwellers of 1400 to 1500 A.D. and burialmound

..builders of about ~00 A.D.

of Prairie Island,.and it happened several hundred years before the village..

"Its not yet clear wheiherPrairie island village founders were from the Cannon River site or were new Colonists," says Dr. Johnson.

Farming pushed hunting, fishing, and wild-food:

collecting into a secondary role. Villages grew larger~.

and-more permanent, with the Prairie Island settle-ment existing.a Couple hundred years.

Dr. Johnson wants to know if it had the features of villages farther south: a Central plaza surrounded by temples and homes.

- "Distinctive tools elsewhere included small trian-gle-shaped arrow heads of chipped stone, like those we,ve found at the village site," says Dr. Johnson.

Pottery of this era found at. the village has more decorative shapes and designs than earlier pottery.

Prairie Island Indians cleared trees from the Mis-sissippi River bank and tilled the rich loose soil with sharpened digging sticks and hoes made of buffalo shoulder blades attached to sticks.

."What happened to the villagers also is a mys-tery," says Dr. Johnson..

"We are puzzled over the.relationship_between early Minnesota In~ians an~~ those of historic times such as the Dakota-Sioux-Assiniboine, Chippewa, and. Iowa-Oto nations.."

A sure bet is that while Dr. Johnson is wrestling with these questions he wouldnt, mind unCovering

.remains of a fort Pierre LeSueur ordered built some where, on Prairie Island in 1696. The outpost was used just a couple years, and ~o far the structures clay floor and limestone fireplace have escaped de-

- tection by any exploring archaeologist..

!7

control rod assemblies.of cadmium-indium.silver alloy, encased in steel, plus.liquid boron injected in controllable amounts into the primary coolant.

RADIATION,BAR RIERS:

Fuel pellets themselves,.zircaloy metal tubing, steel reactor vessel containing control rods.of cadmium-indium-silver alloy in steel tubing and also containing liquid boron in primary coolant water, steel containment vessel, air containment space, concrete con-tainment building, and periodic use of Water barriers, storage container, and filtering...

TEMPERATURES Fuel pellets 4,000° F, average reactor coolanl temperature 576 ° F. Temperature.of river water used to cool condenser will meet discharge standards to be set by the Minnesota.Pollution. Con-trol Agency NET STATION HEAT RATE"

-10,700 btu/hour.

PRIMARY COOLANT: -

Treated water, and liquid boron,-at 576 o F average and.pressure of 2,235 pounds persquare inch in.reactor core.

SECONDARY COOLANT:....

Treated water at 510°.F.and pressure.of 720 pounds per square inch at turbine. Steam flow 7,400,000 pounds per hour.

CONDENSER COOLING WATER" Screened river water Under atmospheric-pressure.

COOLING TOWERS.. "

Structures which allow air to cool water, trickling down over

.corr0sion-resistant panels. Temperature: of condenser cooling water is regulated in accordance with government standards before being returned to river.-

TURBINE.

1,800 rpm, tandem,compound (single shaft), three-cylinder re-heat unit using 40-inch last-stage buckets.

GENERATOR.

659,000.k.va rating,..cooled with 60 pounds per square inch hydrogen gas. Output 19,000 volts, alternating.current.

SUBSTATION OUTPUT:

345,000 volts and 161,000 volts, alternati.ng current, PLANT EMPLOYMENT:

About 95.

PLANT CONSTRUCTION EMPLOYMENT:

Average 1 50 over four years with peak of.about 700.

OVER-ALL DESIGN.AND CONSTRUCTION RESPONSI.BILITY.:

Northern.States Power Company.

AR C H ITECT-ENGIN EER Pioneer.Engineering and Service Company, Chicago.

REACTOR,STEAIVI SYSTEM, AND TU R B IN E-G EN ERATO R S U PPLIER Westinghouse.Electric Corporation, Pittsburgh, Pa.

19

Specifications North.ern. Sta.tes Po.wer Companys PRAiRI E 1 S LAN D Nuclear Electric-Generating Plant LOCATION" 560-acre site 28 miles southeast of Minneapolis-St. Paul, six miles northwest of Red Wing,.Minn., on peninsula named Prairie Island, in Mississippi River. "

FEATURES..

Two independently controlled atomic reactors, two turbines, two generators, supporting equipment, and electric substation. Facil-ities for processing intake and discharge cooling water, nuclear fuel, and radioactive.wastes in solid, liquid, and gas form.

TOTAL COST:

$200 million.,

CAPACITY Reactor #1..; 550,000-kilowatts, to begin operation in 1972.

Reactor //2" 550,000-kilowatts, to.begin operation in 1974.

REACTOR TYPE" Pressurized water.

FUEL:..

Pellets of dioxide uranium-238 slightly enriched by artificial method with uranium-235.

FUEL LOADING".

120,000.pounds of uranium in 121 assemblies in each reactor core, equivalent in energy to 6 million tons of coal. Refueled 40 assemblies at a time, once a year. Other reactor remains operating.

REACTOR CONTROL:

Abso.rption of free neutrons in. each reactor core by 33 movable

PRAIRIE ISLAND near Red Wing, Minn.

Two units of 550,000 kilowatts scheduled to begin operating in 1972 and 1974..

).

NORTHERN STATES POWER.COMPANYS NUCLEAR ELECTRIC-GENERATING PLANTS MONTICELLO near Monticello,,. Minn.

Adding a generating"capacity of 545,000 kilowatts to NSPs.

fast-growing system in 1970.

NORTHERN. STATES POWER-COMPANY 414 NICOLLET MALL,.MINNEAPOLIS, MINNESOTA 55401

July 4, 2008 IXA_t N N E S OTA STATE UNIVERSITy M A N i( A TO Ron.Jotmson, President Prairie island Indian Community Tribal Council 5636 Sturgeon LakeRoad

-Welch, MN 55089.

Mike Wadley, Site Vice President CC: Jim Holthaus, License Renewal Environmental Project Manager Prairie IslandNuclear Generating Plant I7..17 Wakonade Drive Welch, Mirmesota 55089.

Re: update on progress in Bartron village site (21GD02) excavations.

To"the Tribal Council and to Xcel Energy:

We againextend our deep gratitude to the Prairie Island Indian Community and the Tribal.Couneil for your years of support in our continuing research. on the Native American occupations on and around Prairie Islan& We also gratefully acknowledge Xcel Energys cooperation and.support in the Bartl-on viltage research project this year. There are too few examples of this level.of cooperation across -

communities, and we. thank. everyone. - involved for their patience, and sensitivity..

The Red Wing region is of immense.importance in understanding the foundations of historical Indian life stretching from the eastern woodlands out onto the prairies and. plains and from the central Mississippi.

Valley up to the northern lakes. Here, the great nations we now know as the Dakota, Ho-chunk, Ioway, Otoe, and Missouria, among others,.lived, met,. feasted, prayed, traded, married, raised their children, and died..The sites they left.behind.are central parts Of Indian cUltural history and are important to all people as our common human hi story. Archaeological research~isone of the only tools we have to. study.

ancestral lives, and along with.oral history and.oraltradition, it helps us remember, learn from, and honor the past..

Among the major village sites in the Red Wing area, the Bartron village has long remained too poorly understood. Excavations conducted there from the late 1940s tO the late 1960s have never sufficiently been. tied together for us to understand the site as a whole, and indeed there are many questions that were either never answered or in some cases, even asked in the first place. The work we began this summer is designed to provide a basis for addressing some. of these asked and unasked question, and to provide a more synthetic overall impression of the site.- its boundaries,, components, andcondition. Since our analysis is not yet complete, this letter merely gives you some initial information. Please, therefore,.

consider it preliminary and subjectto change as our work progresses, and exclusively referential to the Bartron village site.

What is. talked about here is primarily about the archaeology field school.. The geophysical survey done by Don Johnson is under specific.contract with Xcel and will be reported separatelyi What I can say is -

that it Was successful beyond expectations.in providing data to relocate mound loci and other important DEPARTMENT OF ANTHROPOLOGY 358 TRAFTON SCIENCE CENTER N, MAN KATO, MN :56001 PHoN E 507-389-6504 (V), 800-62.73529 OR 711 (MRS/TTY) - FAX 507-389-6769

areas. The field school goal was.mostly to assess thepotential for contact-era.occupations at the site,, and to investigate a particularly important.feature that Elden Johnson called a "possible wall trench" in his 1968 work. The information here..will be expanded and revised as Emily. Hildebrant completes her.MS "

thesis this fall. Copies of the thesis.will be provided to the Council and Xcel Energy when it.is completed.

Assessment of previous work "

Although investigation of the Bartron site goes back. at.least to the turn of the 20t~ Century, scientific excavations therebegan in 1948 under the direction of Dr. Lloyd Wilford. Wilfords Work, though,.was co ~ned to the cultivated field now owned by Mrs. Charles Suter, and is not germane here. The specific.

work that is relevant to this years field activities is Elden, Johnsons excavations.in. the 1960s.-.

Please not¢ that I do not. wish to impugn Dr. Johnson or cast doubt on th¢ results of his total.body of work..He was a pioneering figure and a fm~ archacologist, and many. of the states s~nior..archa¢ologists today were train¢d.under his tutelage. Indeed, he was among the first archaeologists in Minnesota to.

.stress. the importance of working with descendant communities..HowCwr, it must be acknowledged that some o.fhis methods would not be considered acceptable today. For ¢xampl¢, in 1969 at theBartron.

village site.he had a mechanical grader operator strip th¢ upper 60cm of a 15m by 20m area that he knew to be intact (that is, ufidisturbed). His goal in this Was to look for deep pit features because, in other areas of the site, hc had found particularly important and impressive specimens of pott¢ry,.stone and bone tools, etc. In doing so, :he undoubtedly destroyedother important.information. This would NEVER be done today, and it breaks my heart, to know that it was done then. Yet, at the.time it was considered an acceptable action,, and it Was donein good-faith.. As. well, as you will note below,the results of Iris 1968

.work would have been different if he had not run out of time. His aborted.effort to determine the existence ofa possible wall trench led to a.significantmispercep.tion.in the literature that the current proj.ect can finally correct.

Overall, my assessment.is that he was overextended. He had t0omany students in the fieldand too many excavation traits open at one.time to see and deal With all ofthe.features.andartifacts. that were being....

documented.and. recovered. In addition, his and the students field notes and maps leave many details quite.unclear. Again this waspar for thetime and is not a real criticism of him, but rather of State of the "

- discipline in the late 1960s, History of investigations and status.of data Although we have some information on the site excavations that took place in 1948, 1968, and.1969,. we also know that limited excavations took place in 1960, 1967, and 1980. As.yet, no field notes, maps, or reports..have been found that provide details, on the 1960 or 1980work. There are field notes from the 1967 work, but no map has been located and thus the excavation uni. ~ts cannot be tied..to any real world -

coordinates, or. to other excavations atthe site. With specific regard to the 1980 work, the detailsmaybe included With other data on that years work on Prairie Island, but.this has yet to be determined.

The artifact collections of the Minnesota Historical Society (MHS)include materials from the 1948, 1967, I968, 1.969, and 1980 investigations, but. the whereabouts, of the 1960..artifacts is unknown. The original field maps from Wilfords t948 work seem to be lost,.although some data on the location of the excavation units is contained inthe student" s field, notes (interestingly, Elden Johnson was the mapper that year) and maps were prepared for Marshall MeKusicks 1950s MA thesis at the University of.

Minnesota. The MHS has.graciously lent us the original, hand-drawn excavation maps from the 1968 and 1969 work so that we cancompletely redraft a proper map (the map presented in Gibbon 1979, the only published map,.has some major errors and omissions). All in all, the records are in comparatively good "

and complete shape, with some notable exceptions. Finding the.missing notes andartifacts remains.an important.goal of our work, and the MHS is assisting in this effort. -

Precontact components For many y¢ars,.amataur artifact collectors and professional archaeologists have known that the primary occupation at the Bartron villag~ was what. we call "Oncota".. This archaeological taxon, first used back

.inthe 1920s, is the word w~ us~ to coll~ctiwly describe the material culture. (ways Of making stone and~

bone tools and pottery) ~)f thos~ whom w~ now know to be ancesWal.Chiwer¢, but also som~ Dakota and Dh~gihaSiouan-speaking p~oplCs, itis not a wry useful t~rm an.ymor¢, but i~ is what.w~ hav~ to work.

with.

Because of the. differences, in material culture seen. in the various Red Wing villages,, archaeologists have long puzzled over the fascinating dynamics of interaction among peoples from many separate Native American groups across.the region...Among thesevii!ages, researchers believed that the Bartron village most clearly contained the local expression of Oneota. culture, and was.probably ancestral to the Oneota

- - culture seen slightly later in the Blue Earth and possiblythe LaCrosse regions. The Oneota occupation at theBartron village gained, importance to archaeologists because, among the Red Wing villages, it seemed to be relatively early and. "pure"- that is, unaffected by what seem to be influences from other groups.

living elsewherein the Midcontinent. Non-local influences.are seen primarily at other large villages such as Mero, Bryan, and Silvemale.that date to a similar time - ca. A.D, 1100 - 1300. Johnsons description of apossible wall trench at Bartron was, therefore, particularly.significant because such structures were typical of Middle Mississippian culture, centered near St. Louis, Missouri, but were not typical of local-.

construction techniques. If present, it would be the only example.of a Mississippian wall trench.structure in the region.... Unfommately, even though Johnson was circmrmpect, this aspect of the site somehow became more factual than potential, and itentered the literature.

Radiocarbon.dateson Bartron site materials acquired at different times by Elden Johnson and Orrin Shane

.(then at the Science.Museum of Minnesota) were ambiguous,, suggesting either an early, ca. A.D. 1050,.or a late,.ca. A.D. i400 date for the site. This led to widespread speculation and debate in the archaeological

- "literature, especially because the origins of Oneota cuRure remain obscure. Some researchers suggest that Oneota culture is the result of non-local (i,e. Mississippian). influence on local, Late Woodland peoples starting around A.D.. 1050, while other researchers see culture change as a locally driven process

-happening.. independently of and prior to Mississippian influences spreading into the area. Thus, Bartron has become akey site in understanding the processes of culture ch.ange and the emergence of Oneota culture in the region.

One of. the. interesting.preliminary findings of our work at.the site.this year is. that there.appears to be -

more of a Late Woodland (ca. A.D. 700 - 1000) presence than suggested by earlier work at the site. Late Woodland occupations are pfimaiSly differentiated from Oneota occupations bythe pottery: Late Woodland pottery is tempered:with grit and decorated with Continuous bands of.textile and tool impressions, while Oneota pottery is tempered with crashed shell and decorated with discrete geometric patterns of trailed, lines and punctates. The reasons why we recovered, more Late.Woodland than Oneota materials at the.site this year are unclear.

We were fortunate to discover seven pit features (basin-shaped pits that Contain concentrations of artifacts and organic remains)., each of Which.we carefully excavated, importantly, the mystery of the possible -

wall trench, was solved by the. discovery of these pit features.. In excavation trait # 10 from the 1968 work, Johnsons students had excavated to 40cm in depth when he saw soil staining. To.Johnson, this suggested a wide, shallow trench extending to the northeast and southeast (that is, forming a fight angle). He "

expanded his excavation unit to the north and south.to try to. follow the pattern, but it was not apparent, and being out of time, he abandoned the effort. Upon re-excavating.the unit and digging a mere three centimeters deeper (to 43 cm), wefound that the soil staining was in fact due to the presence.of four large pit features, the tops. of whichhad blurred together in the soil.. Hence, therewas no wall trench at all and

we can now formally reject this as PosSible evidence.of Mississippian influence in Red Wing. This is an important clarification that has broad implications for Red Wing and Mississippian studies in general.

The functions of the pits is as-yet unlmown. The-soil was collected in its entirety and is being processed to recover even the smallestartifact (down to 0.25ram). There will. be adequate wood charcoal to acquire high precision radiocarbon dates of these features, and this will hopefully put to rest at. least some of the questions about the timing of the Late Woodland. and Oneota occupations at the site. Xcel Energy has offered to fund dates for two of the features following the protocols I established with Lawrence Livermore National Laboratory. This will be a very significant step forward in understanding.the site and in refining our tmderstanding of Native American.heritage in the area.

Historical components One of the most intriguing aspects of the Bartron site is the presence of what. are described as.."contact era" items such as glass beads, scraps of brass, and clay pipe fragments. Johnson reported finding such items in the 1960 and 1968 work, and he suggested that they may relate to the long-lost 1694-1696 fur trading post that Pierre Charles LeSueur established among, the Prairie Island Dakota. Importantly, when Johnson described the possible w all.trench,. he suggested that it was approximately a meter wide and had a closed comer, which would havebeen typical of Frenela-period outpost ccmstmction,. The contact

- period in Minnesota. lasted, from ca. 165.0 to 1850, and is one of ~e.most important and yet poorly known periods in Red Wing. archaeology.. In part.this is because it is a relatively brief time span, but also because the. artifacts are. quite rare and most of the contact era sites have since been destroyed by development.. (such as Chief Red Wings camp where the city of Red Wing now.exists). This period is..

essential to studybecause it is precisely here that archaeology and oral tradition intersect.

As noted above, the.possible wall trench was not a wall trench, and therefore it clearly cannot be evidence of LeSueurs fort. Further, we recovered no artifacts dating to the contact era during this field season.

Thus, this component of theBartron site remains obscure but nevertheless fascinating and important to continue researching....

Condition and extent When Wilford began his investigation in 1948, he noted that part ofthe site was in a cultivated field.and part was in pasture. By the.late 1960s,the pasture had-grown into woodland, and by 2008, the woodland had become a dense forest. To facilitate the geophysical.and. archaeological investigations,. Xcel personnel cleared outthe underbrush..All mature vegetation was left standing..The cultivated part of the.

field has beenunder continuous use.- Interestingly, although Johnson suggested that the wooded portion.

of the site had notbeen cultivated, our excavations did reveal the presence of a shallow plow,zone, in the soil. Itis therefore likely that the site. was cultivated for.a short period long enoUghbefore 1948 forit to have.become.a grassy field. This conclusion is supported by aerial phot0graphsdating from 1938 and 1949. -

Based on the geophysics and the archaeology,.we can conclude that the site is in good condition. This includesbohh the.cultivated and wooded portions of tlae village and associated mound go.up located to the southeast.. Although unapparent on the surface, the. locations of mound remnants, traces of houses and

.... refuse pits, as well as possibly a.palisadeor log wall, are clearly visible, The northern, site limits were" formerly drawn at where the old Nauer farm access road was, but the geophysics.indicates that the.site persists past that location..Further research using geophysical and archaeological methods should be undertaken in these.specific areas to continue to assess theextent.and character of the site.. Clearly, the village area and mound remnants that are in the cultivated.field will continue to be disturbed, and it would be.worth discussing some sort. of minimization efforts, such as no-till fanning, with the landowner..

Conclusions The research undertaken at.the Bartron village site this summer was successful in answering our research goals. Although we did not fred the French presence we were looking for, "negative" fmdings still give.

us information about the village, site. The project also attracted good attention to the importance of this

- work and of cooperation among researchers, descendant communities, landowners, and state and federal agencies..Our findings have already and will continue.to help.refine our knowledge Of Native history in the Red Wing..area, and.we.look forward to collaborating on future work. Please feel encouraged to ask any questions you may.have. We will be intouch again soon with further information.

Sincerely, _i_-.

Ronald C. Schirmer, Ph.D..

-Assistant Professor

-Department Of Anthropology Minnesota State University, Mankato Graduate Student

.. Department of Anthropology Minnesota State University, Mankato

Information published by IPPNW I UIm Physicians Initiative-January 2008

- Childhood Cancer in the Vicinity ofNuclear Power Plants The 2007 "KiKK"* Study-IPPNW Physicians lssu.e Warning:

"Young children develop cancer more frequently when they live near nuclear power plants (NPP).

it has to be assumed that radioactive emissions from NPP stacks are indeed not as harmless as,previously believed..

-Now it,is time to act..

UIm, January 11~ 2008 Young.. children living near to German nuclear power plants develop cancer and leukaemia, more frequently than children living further away from. them. There.is a.60% increased rate of cancer and.. approximately 120% of leukaemia. These. are. the findings of the "Epidemiologica.i. Study of Childhood Cancer in the Vicinity of Nuclear Power Plants" (KiKK Study), commissioned by the German Federal Office for Radiation Protection (BfS). Although the design of the study, carried, out.by the Mainz Cancer Registry, i.s generally held to be correct,, interpretation of the studys findings isvigorously disputed by the authors~. Indications of an increase in the incidence of childhood cancer near nuclear power plants have been found for over 20 yearsz, but they have.not as yet.been. taken sufficiently seriously. The correlation has been unequivocally confirmed..bythe KiKK study.

Now it is time to act. -

Background to the 2007 KiKK Study The KiKK Study was called for i.n 200.1 by IPPNW and the. Ulm Physicians initiative in. a large-scale public relations cam.paign~, because several, studies carded out by Dr. Alfred KSrblein of the Munich Environmental Institute~, -including a study on NPPs in the Bavarian regioninitiated by IPP.NW-had shown a significantly higher incidence of childhood cancer in the proximity of nuclear power plants. Only after massive pressure and over 10,000 letters ofprotest to the authorities and ministries.did the. Federal Office for Radiation Protection (BfS) accept the necessity for further studies~. The study was then commissioned by the.BfS in 2003 to be carried out. by the. Mainz Cancer Registry~.

There had already.been reports of significant increasesin the levels of leukaemia around English nuclear, installations, in the 1.980s. There were also sharp increases in rates of leukaemia around the reprocessing, plants at Sellafield and L.a Hague.

An increased incidence.of ieukaemia found close to the. Kr0mmel. nuclear.power plant caused much concern from the beginning of the 1990s onwards. Few studies o.n the subject were. known,.

however, and most of those that existed Showed nothing conspicuous in the vicinity of nuclear.

power plants-at least in the official versions:

1992~ and 1997e - Two studies by the Mainz Cancer Registry (Director: Prof. Michaelis, institute for. Statistics and Documentation of the University of Mainz (IMSD)), covered the periods of 1980 to 1990 and 1980 to 1995 respectively. The childhood cancer rates in the vicinity of the 20 German nuclear installations (of which three. were decommissioned nuclear power plants and two were research reactors) were examined. Main finding-nothing conspicuous~.

.,,KiKK" stands for,,Epidemiologische Studie zu Kinderkrebs in der Umgebung von Kernkraftwerken" (Epidemiological

The "Michaelis" study has been consistently criticised since 1992 by Prof. Roland Schoiz-in numerous IPPNW~° ~ and other publications~ ~, A renewed analysis of the. data in the IMSD studies.in 1.998 by Dr. KSrblein and Prof. Hoffmann~" showed that there was a significant increase in the rate of childhood cancer within a radius of 5 kilometres. The increase was to be found 0nly when operational nuclear power plants were taken into account, not the decommissioned, plants,

- nor the research reactors. The increase was only found amongst infants under the age of 5 years old.

Methodology and findings, of the 2.007 KiKK Study The results of the KiKK.study.were published in December 2007 in the European Journal of Cancer~ and in the International Journal of Cancer~. The study covered all 16. large reactor locations where, the 20 nuclear power plants.in Germany were in operation during this period of time (period of study: 24 years, 1980 -2003). Since the Lingen and Emsland..locations are only two kitometres apart, they were combined, into one study region. In.the first part. of the study a total of 1592 under-fives with cancer were compared to a control group of 4735. children. The distance between, the.childrens homes and the.power plants was.precisely determined to within 25-meters.

The main. questions posed by. the study were: "Do. children under five years old more frequently develop cancer when living near a nuclear power plant?" and " is there a negative distance trend?"

(In other words: does the. risk increase the nearer one lives to the.plant?) The results showed not onlya ~60%.increas.e in the cancer rate and a 117%. increase in leukaemia in.infants within the 5 kilometre radius, but also a significant increase in the risk of cancer and Ieukaemia the closer one lived to the nuclear power plant.

In. the second part of the study, which covered a shorter period of time and a selection of.

diagnoses (leukaemia, lymphomas and tumours of the central nervous, system), it was tested

- whether other risk factors (confounders) could have had any appreciable effect on the. main result ofthe study -.the negative distance trend. This proved-not to be the case for any of the studied.risk factors. The proximity of residence to the nuclear power plant remains the only plausible influencing factor.

On the discussion on the "small number" of cases After the findings of the study were published in.December 200.7, the authors, frequently.

emphasised appeasingly, that the study basically "only" dealt with a small number of cases of cancer. 37. cases were observed where 17 would have been. expected statistically. This means that

- in a period of 24 years there was less than one additional le.ukaemia case a year. The 20 additional cases were only to be found within the 5 kilometre radius and were all cases of.leukaemia. The reciprocal distance rule. implicit in the study, however,, adds up to a total of 127 additional cases amongst infants for the whole region under study.

Moreover, it can be assumed that such effects do not.confine themselves to small children. Older children and adults could, also be affected. However, the rates of cancer development amongst these groups have not yet been the.subjectof a. comparable systematic study anywhere in the world.

it seems to me that the argument is significant that the KiKK study,, in. its methods and the questions it posed, was not set up to determine the exact number of additional cases of. cancer at all. One can. always find larger or smaller numbers of ill children according to the random selection of the size of the study area and using different distance rules. The latest. KiKK study has a

.methodological strength, however, in testing the distance. trend (which was also. the main question.

posed by the study). This overcame the disadvantage of classically-, dividing the area into. circular sections. But the KiKK study is inappropriate for determining the. absolute..number of cases. The authors reference to the small number of cases is obviously meant to soften the highly charged controversy.over the results of the study. In any case, the study proves that there is an increased risk that correlates to the proximity to nuclear installations. That the absolute number of additional cancer cases is not higher i.s in part due to the fact that the area around nuclear power plants is usually thinly populated°

Controversial interpretation of the KiKK study - was it only coincidence?

The authors of the study were. at first surprised by the results, they had arrived at. They.quickly pointed out that the raised levels of childhood cancer and ieukaemia in the vicinity of nuclear power plants could, not be explained by radioactive emissions. They.claimed that the doses of radioactivity calculated, to be in the Vicinity of nuclear power plants are below the average dose from.natural background radioactivity. Since this is not compatible.with current radiobiologicai thinking, they did not rule out the possibility of coincidence as an explanation.

The findings of the 2007 KiKK.study invalidate those of the previous "studies. by the Mainz Cancer Registry (IMSD 1992 and 1997). This should not really ~be a surprise, since KSrblein had already.

pointed these effects out many times, as had KSrblein and Hoffmann in their reanalysisof the

.IMSD study i.n 1998. For this.reason, KSrblei.n was strongly attacked by the Mainz.Cancer Registry

- and accused of "data dredging"~. However, the 2007 KiKK study completely confirms the IMSD reanalysis of 1998. The authors.belonging to the. Ma.inz Cancer Registry have also admitted in the meantime that their earlier studies had already shown an.increased cancer and leukaemia risk for infants living in close proximity to German nuclear power plants.

So what is the cause? "Coincidence" already has a. long. and sad tradition as an ultimate and

" helpless example, of interpretation in radiotogical causality research. Let me remind you.of the -

attempts made to explain the raised., levels of childhood leukaemia inthe area near the Kr0mmel power plant and Geesthacht nuclear research.centre. Previous..inexplicable clusters were given as the explanation for another inexplicable cluster. Was it once again simply coincidence?Yet coincidence as an explanatory.modelwas clearly held to be improbable by the. external experts group, commissioned by the BfS to supervise the drafting, the execution and evaluation of the KiKK study~~. In referring to.coincidence, the Mai.nz authors are ignoring the current state of research.

Already in the summer of 2007, a comprehensive meta-analysis by Baker et al. on leukaemia in children living near nuclear power ptants~.caused a sensation. They examineddata contained in a total of 17 international studies carried out in Germany, Spain, France, Japan and North America during the. period between 1.984 and. 1999. EpidemioIogists at the University of South Carolina discovered an enhanced risk of between 14 and 2.1%. of developing leukaemia for children ~under nine years of age, depending on distance. All. ofthe people, examined under the age of 2.5 had an increased morbidity probability, of about7-10%, and the rates Of mortality were raised.by 2-18%.

Correlation. between the rate of morbidi,ty, emission measurements, calculation model for radiation exposure and the biological effects of radio.nuclides in Germany,.children that are living near nuclear power-plants develop cancer and ieukaemia more frequently that those living furtheraway. This has long been only a supposition, but has nowbeen clearly proven and is officially accepted~°.

If emissions have been correctl-y measured by monitoring the areas, surrounding nuclear installations, as has been claimed by both the NPP operators and the regulatory authorities, then

.either the currently accepted calculation models for determining radiation exposure of local residents are incorrect, or the biological effects of incorporated radionuclides have been badly underestimated, at least foryoung, children or embryos:

The results of the KiKK-study compel us to critically review not only the measurement of emissions by the operators but also the rules for calculating dose measurement and the risk models on which they are. based.. Any of these three steps, could help solve the contradiction between the allegedly low doses and.the severe effects. referred to by the authors.

A separate inquiry into.the boiling-water reactor design type is also necessary

.Boiling water reactors (BWR) have only one main cycle in their design. Pressure water reactors.

(PWR) have two separate main cycles, which means that BWRs have one less barrier holding back radioactive material from the surrounding areaThe weak point can.be found in. the machine room of the.NPP where highly radioactive hot steam is transported out of the reactor itself to the turbines.

in order to eliminate one individual location as the sole cause of the morbidity rate, the data in the study was assessed 1.6 times, each time excluding one location, in every case the exclusion did not change anything related to the main. result of the study - a negative distance, trend. It. was not tested, however, whether there was a difference in risk levels when comparing BWR or PWR design types.This question could beanswered easily enough using the existing study data.

Them is enough evidence to. show thatthe. BWRs in Germany (currently.B.runsbOttel, KrOmmel, Phillipsburg i, Isar. 1, Gundremmingen B + C; in the past W(3.rg.assen) have higher levels, of emissions. According. to the annual reports.of the.government, environmental, radioactivity and -

- mdi.ation exposure=~ of BWRs are appreciably higher than. those of PWRs, though within the currently accepted limits.

It is now time for us to act. The indications,over many years that there are increased levels of morbidity near to.NPPs have,now been scientifically proven by the KiKK,study..

N.oone can rule out the possibility of an increased risk for older children and adults living near NPPs, ASystematic investigation, of the type of the KiKK study.has still to be carried out.for these groups.

The previous mode of. measuring emissions and reporting them needs to be..put to the test.

We c~n no longer rely o.n the information given by the NP.P operating company. There needs to be official monitoring without any gaps and measured, values.must be made public.

Previous assumptions about radiation risk, and the emission limits for radiation that are based on these, need to becritically re-examined and adapted to current international research findings..

In. addition, the data in the KiKK study should-be separately assessed according to. whether the location is a BWR or.PWR.

We should primarily think about the people affected - the precautionary principle is. long

overdue, Further cases of cancer near to NP.Ps have to. be prevented. The only kind of reactor that does not present a cancer risk is a decommissioned reactor.

Reinhold Thiei, Spokesperson for the Ulm Physicians Initiative Translated by Xanthe Hall, IPPNW Internet links (in German) www.ippnw-ulm.de www. bfs..de www.ilol0nw.de -

www. umwelti nstitut, orq.

www. a Ifred-koe rb lei n. de www. kind.erkrebsregister, de

Acknowledgements For feedback, thanks go to the following people: Dr. Winfrid Eisenberg, Dr. Veit GSIler, Prof. Dr.

Wotfgang Hoffmann, Raimund Kamm, Dr.Alfred KOrblein, Prof..Dr. Dr. Edmund Lengfelder, Henrik Paulitz, Dr. Sebastian.Pflugbeilo Prof. Roland Scholz und Karin Wurzbacher.

Thank you to the Federal Office of Radiation Protection for the constructive cooperation since July 2001, and for enabling and financing the KiKK study. -

Thank you to the authors of the Cancer Registry at.the.University of Mainz for conducting the 2007 KiKK study, using a correct design (that was put forward by the external group of experts, that supervised the study).

Sources i Unanimous Statement by the expert group commissioned by the German Federal Office for Radiation Protection on the KiKK Study (in German, no English -version available), point 9, 5. I2.2007, http://www:bfs.de/de/kerntechnik/papiere/Expertengremium.htmI 2 Thiel RKinderkrebs um Atomkraftwerke " Qbersicht fiber nationale und intemationale Studien, in IPPNW background information brochure,,Nebenwirkungen der Atomenergie", IPPNW 2002, http://www.ippnw-utm.de/text_ueb,kinderkebs.htm-3 Thiel R Kinderkrebs um Atomkraftwerke, Chronologic eines 10-j~hrigen Engagements.der IPPNW und der Ulmer.

~rzteinitiative, 2.12.2007 http://www.ippnw-ulm.de/071202-Chronologie-Kinderkrebs.pdf 4 http://www, alfredkoerblein :de/

5 Protocol of meeting.between BfS, IPPNW and the Munich Environmental Institute, Kassel, 11.07.2001. (Original in German, with author) 6 Thiel R, Paulitz H, Kinderkrebs am Atomkraftwerke, IPPNW Working group on nuclear energy press release, 19.03.2003, http://www.ippnw-ulm.de/text_krebs-akw0303.htm 7 Keller B, Haaf G, Kaatsch P, Michaelis J, Untersuchungen zur H~ufigkeit yon Krebserkrankungen im Kindesalter in der Umgebung westdeutscher kerntechnischer Anlagen. 1980-1990, IMSD, technischer Bericht, Mainz, Institut Medizinische Statistik und Dokumentation der Universit~t Mainz, 1992 - and: Michaelis J, Haaf G Kaatsch P, Keller B, Krebserkranktmgen im Kindesalter, D)£, issue 30, 24.7.92, pp. 1386-1390 8 Kaletsch U, Meinert R, Miesner A, Hoisl M, Kaatsch P, Michaelis J, Epidemiologische Studien.zum Auftreten on Leukt~mieerkrankungen bei Kindern in.Deutschland, Bonn, Der Bundesminister fiir Umwelt, Naturschutz und Reaktorsicherheit, (I 997-Dr. Angela Merkel) 9 h ttp ://www. kinderkreb sregi st er. de 10 Scholz R, WeiI nicht sein kann, was nicht sein.darf, IPPNW-FORUM, Issue 8,.December 1992, pp. 23-31 1 ~ Schol.z.R, Kernkraft und Kinderkrebs, in IPPNW-Studienreihe, Band 4 I st edition 1993, Bedrohung des Lebens durch radioaktive.Strahlung, pp.. 57-63.

12 ScholzR, Zw61f Anmerkungen zur IMSD-Studie, Strahlentelex, No. 130-131, 6th year, 4.6.1992, pp.. 1.-9

~3 Scholz R, Weil nicht sein kann, was nicht sein daft,.Kommentar zur Michaelis-Studie aus Mainz, in:. Kttufliche Wissenschaft, Experten im Dienst vonIndustrie und Politik, Bultmann/Schmithals (Ed.), Knauer-Verlag 1994 -

14 Koerblein A, Hoffmann W. Childhood Ieukaemia in the vicinity of German nuclear power plants, Medicine and Global Survival Vol.61(1999), pp. 18-23 15 Spix C et al, Case-control study on childhood cancer in the vicinity of nuclear power plants in Germany 1980-200.3, Eur J Cancer (2007), doi: 10.1016/j.ejca.2007.10.024 16 Kaatsch. P et al, Leukaemia in young children living in the vicinity of German nuclear power plants, Int J Cancer (2007) 17 Statement by the Mainz Cancer Registry on their homepage of. 19.6.200.1, http ://www.kinderkrebsregister.de/ste llungn ahme0601.html Is Unanimous Statement.by the expert group commissioned by the German Federal Office for Radiation Protection on the KiKK Study (in German, no English version available), point 10, 5.12.2007,.

http://www.bfs.de/de/kemtechnik/papiere/Expertengremium.html I9 Baker P.J., Hoel d.G. (2007), Meta-analysis of standardized incidence and mortality rates of childhood leukaemia in proximity to nuclear facilities, European.Journal of Cancer Care, No. 16, pp. 355-363 -

20 Weiss -W, Background information on the KiKK Study, Federal Office for Radiation Protection, http://www..bfs.de/en/kemtechnik/papiere/kikk.html 21 Annual reports of the Federal German Government, Umweltradioaktivit~.t und Strahlenbelasmng, published on the site http://dip.bundestag.de. The report from 2001, 14/9995

.http://dip.bundestag.de/btd/14/099/1409995.pdf, for instance, shows four times.the amount of radiation in the spent air coming from NPP Gundremmingen that contains two BWRs.