ML19309B578
| ML19309B578 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/1980 |
| From: | Bross I ROSWELL PARK MEMORIAL INSTITUTE |
| To: | Vollmer R NRC - TMI-2 OPERATIONS/SUPPORT TASK FORCE |
| References | |
| FOIA-80-198 NUDOCS 8004040320 | |
| Download: ML19309B578 (3) | |
Text
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Irwin D.J. Bross. Ph D.
Director of Biostatistics Roswell Park Memorial Institute 666 Elm Street Buff alo. N.Y.14263 No oo.a.oao aere e.eeeeees snow to ceaserves se eenscuas ottic>es see.s.one of the esm.a.eireieiof Roomest Port 44esstorial lastetwte or of the N Y Siete Hearth Cepertment
>brch 31, 1980 Richard H. Vollmer, Director Three Mile Island Support United States Nuclear j
Regulatory Commission Washington, D.C.
20555
Dear Dr. Vollmer:
In your letter to me of January 18, 1980, you enclosed a
" Statement of Policy and Notice of Intent to Prepare a Programatic Environmental Impact Statement (November 21, 1979)".
Since then the date for a final decision on the dumping of radioactive gases and liquids I
has been set for April 8,1980, but I have not received the promised PEIS. Therefore this 1ctter has three purposes:
(1) As a letter to go into the public record opposing any dumping of radioactive materials at Three Mile Island.
It makes no i
engineering or public health sense to dump Krypton as the first step 4
when the later steps in the " clean-up" have not been specified program-atically.
(2) As a request under the Freedom of Information Act for full report of the inventory of radioactive wastes in the TMI containment with the damaged reactor (either as part of any competent PEIS or as 4
information from NRC files).
In addition, since virtually all of this radioactivity would have to be removed from the containment if the i
current (5 rem per year) NRC exposure standards for workers would ever i
be met, the specific disposition planned for each item of the inventory should be given (e.g., vented into atmosphere, discharged into river, removed by truck, etc.).
This information is clearly essential for any valid Environmental Impact Statement so it should be readily available.
(3) As a letter protesting the NRC violation of intent and letter of the laws concerning public participation in the decision-making process. The information needed for an informed public response and the time required to develop an alternative Environmental Impact Statement has not been forthcoming. This is clearly a decision which should not be made without extreme careful consideration or without full information and the decision set for April 3, 1980 should be postponed until these conditions are met (at least 90 days),
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o Richard H. Vollmer, Director March 31, 1980 Page 2 In support of the above purposes, the following main points will be made without extensive back-up, the back-up being available if NRC holds additional hearings.
(1)
It is inexcusable to release any radioactivity into the environment until the final disposition of the TMI containment with the damaged reactor is decided.
If a major option, entombment, is the final disposition, no release of radioactivity would be required.
(2) The refusal of NRC to consider entombment involves an unreasonable application of NRC regulations to a situation (e.g., the TMI accident) that was not originally anticipated. Eventually, compliance with the regulations will eventually be recogni:ed as an engineering impossibility. The current 5 rem per year NRC standards for exposure of workers cannot be achieved with the present state of the art in decontamination.
(3) Since over 99.999% of the 100 rem per hour reported by TMI sensors would have to be removed, since transport of radioactive gas and liquid by truck is infeasible, and since the only alternative is dumping the radioactivity in the environment, the entire inventory and not just the Krypton gas must be considered.
Each dumping is irreversible.
However, no dumping would make sense unless the entire inventory of radioactive materials is removed. This inventory has not been fully reporced.
It may not even be known to the NRC since there is limited and only indirect information on the conditions inside the containment.
Nevertheless it would be folly to proceed without some overall inventory estimates since this is required to meaningfully evaluate environmental impact.
(4) On the basis of sketchy evidence so far released it is possible to make only rough ("ballpark") estimates of the overall effect of the dumping of the TMI radioactivity. However, the exposure to this radiation (even if released in conformity with NRC standards--a smaller dose over an extended period) is probably going to produce some 5000 radiation casualties in the population downwind or downstream from TMI.
The casualties would range from serious (but invisible) genetic damage to deaths from leukemia or other cancers after 10 or 20 or 30 year latent periods. The population undergoing this serious risk will have little or no. prospect of compensation.
(5) The net effect is that the NRC is prepared to authori:e what amounts to a rerun of the disastrous decisions made by other federal agencies in conjunction with the weapons tests at Big Smoky and-elsewhere.
The difference is that the reported 970 millirem (average) exposures at Big Smoky are now known to double the risk of leukemia and to have a wide range of other adverse health effects among the servicemen who were exposed. Since dosages in the one rem range (100 millirem to 10 rem) are possible from the dumping, the claim that these exposures are
" harmless" is now known to be scientifically false.
a
O Richard 11. Vollmer, Director March 31, 1980 Page 3 (6) Under these circumstances, all Americans who live in the general vicinity of TMI have good reason to believe that their health and safety will be endangered bg any dumping of the radioactivity at TMI into the environment. They have good reason to be alarmed, enraged, and to take action in defense of their lives and the lives of their children. A decision to go ahead with the dumping would constitute reckless endangerment of the health of thousands of Americans and probably criminally negligent homicide as well. h'hatever happens from here on will be on the head of the Nuclear Regulatory Commission and of President Jimmy Carter.
The above points support the three stated purposes of the letter. The purpose of the Freedom of Information request is to enable more accurate and precise calculations of the actual environmental impact of the dumping of radioactive materials.
I hope the NRC will comply.
Very sincerely yours, Irwin D.J. Bross, Ph.D.
Director of Biostatistics IDJB/mak CC: Open