ML20050C218

Forwards RR Holt Comments on Mitre Corp 820204-05 Psychological Stress Workshop.Proposed Independent Assessment of Probable Environ Impact of Restart Would Improve NRC Credibility

ML20050C218
Person / Time
Site:	Three Mile Island
Issue date:	03/18/1982
From:	Jordan W HARMON & WEISS
To:	Regan W Office of Nuclear Reactor Regulation
Shared Package
ML20050C219	List: ML20050C218 ML20050C221 ML20050C227
References
NUDOCS 8204080297
Download: ML20050C218 (4)

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HARMON & WEISS 47251 STREET,N.W.

SUITE 506 TELEPHONE G All McGREEVY H ARMON WASIIINGTON, D. C. 20o06 E LLY N R. WEIS S caOz) a33-8070 WILLt AM S. JORDAN, llt OF COUNSEL LEE L. BISHOP L LOWAY DIANC CURRAN A LY N NE BERNABE1 Mard 18, 1982 #

LUCIA S. ORTH g

b RECENED William H. Regan, Jr. m .o Chief, Siting Analysis Branch -

APR 07198 i U.S. Nuclear Regulatory Commission 8 anca ra m y,2 6 4550 Montgomery Avenue F**m O Room 5109 g, *maa Bethesda, Maryland //

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Dear Bill:

I am enclosing a copy of Dr. Holt's " Comment on Psycho-logical Stress Workshop," which he submitted to Mitre.

I believe he has already sent a copy to Don Cleary.

l You will note that Dr. Holt has responded to two major i

points that have been raised by your staff. First, he has l set out a clear theoretical and conceptual basis for approaching l the prediction of psychological health impacts. Second, he has outlined the essentials of the type of study that is needed to make the required predictions. Since this was written under the deadline for submittals to Mitre, it does not include extensive references, but is similar to the workshop discussion itself. We can provide references and supporting materials as necessary. In addition, we are prepared to. advise or assist in developing the instruments and other materials to be used in further research.

We emphasize three points based on Dr. Holt's discussion, the Mitre workshop, and the meeting in Middletown. First, 3

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HARMON & WEISS Ltr. to William H. Regan, Jr.

March 18, 1982 Page 2 the existing TMI studies were not intended to and do not address the specific question of predicting the psycho-logical health impacts of restarting TMI-1. Accordingly, a study such as that outlined by Dr. Holt is necessary to comply with the Court's mandate.

Second, the recent false alarm that we discussed at length in Middletown was a highly significant event for those living in the area and appears to have triggered an unsually high rate of " unobtrusive indicators" in the community, including particularly a high rate of emergency ambulance calls. Based on the statements of PANE's members at the meeting, it also resulted in a very high level of concern and even a flight reaction seemingly out of proportion to the threat, or even the perceived threat. On their face, these appear to be indicators of a high level of chronic stress still existing in the area almost three years after the accident, stress that continues, although theoretically the stressor has been partially removed by the fact that  :

I neither reactor is in operation.

In this circumstance, it is crucial that the NRC under-i take a careful study of the false alarm incident and similar I incidents since the accident. This is particularly important i in view of the Mileti unobtrusive indicators study, which I understand to have found very little, if any, significant

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HARMON & WEISS Ltr. to William H. Regan, Jr.

March 18, 1982 Page 3 impact. It may be that existing chronic stress levels do not significantly change such indicators in normal circum-stances, but that incidents such as the false alarm do cause unusually high rates of such indicators, deinonstrating the continuing stress levels. Accordingly, the unobtrusive indicators during and after the false alarm should be examined. The individual reactions to the event should also be studied through the research proposed by Dr. Holt.

Third, we are concerned that restart may be seen as a single event, throwing the switch, that will occur on a given day, and after which the stress will gradually diminish.

That concept misses the entire point. Restart is not a single event, but a continuum that lasts as long as the reactor is in operation and until it is decommissioned. No doubt particular events such as the restart itself will be times of higher stress, although it would not suprise me if the days surrounding restart itself would not be a time when i

there is a significant perception of threat simply because everyone will know that GPU is paying very careful attention because it is under such close scrutiny. The problem comes afterwards when GPU is perceived as paying the same attention to its responsibilities as it was on March 28, 1979. In any event, the point is that the threat to psychological health I

derives not only from the moment of restart, but from the

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l Ltr. to William H. Regan, Jr.

March 18, 1982 Page 4 ever present spectre of the reactor in routine operation.

This must be taken into account in any studies undertaken or conclusions reached by the NRC.

Finally, I want to express our appreciation for the meeting in Middletown. While I am sure you realize that PANE remains ~ skeptical in dealing with the NRC, we welcome what I

we viewed as your responsiveness during the meeting. I also appreciate your commitment to ignore or extent arbitrary and I artificial deadlines in order to assure that you undertake a responsible evaluation of the issues. We will work with you in that spirit. I suspect that the perception of an honest, complete, and unbiased effort in preparing the Environmental Assessment could do more than anything else to improve the credibility of the NRC in the area, and perhaps even to mitigate some of the existing stress.

Sincerely,

/A 2 ys William S. Jordan, III cc: George F. Trowbridge, Esq.

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