ML20112H414

Motion for Reconsideration of Commission Order CLI-84-22 & Opening of Hearing.Svc List Encl

ML20112H414
Person / Time
Site:	Three Mile Island
Issue date:	01/15/1985
From:	Aamodt M, Aamodt N AAMODTS
To:	NRC COMMISSION (OCM)
References
CON-#185-110 CLI-84-22, SP, NUDOCS 8501170130
Download: ML20112H414 (107)

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In the Matter of ) .

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l. METRCPOLITAN EDISON Col *Plu;Y, ET AL. ) Decket No. 50-289

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(Threr. Mile Island Nuclear Gencratin;, )

Station, Unit No. 1 )

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AAMODT MOTIO: FOR RECONSIDERATION OF COF2:ISSION ORDER CLI-84-22 AND l

CPENING CT A HEARING l

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Jancary 15, 1985 Ner.an O. and Marjorio Aareft, h presentatives The Asr.odt Ter'.ly, a party to the T!!!, l' nit 1 Festart Pro;udin e j . . .

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'e 1.0 INTROD*.*:TIO:;

on June 21, 1984, the Aamodts filed a motion with the Nuclear Regulatory Ce mission concerning an elevated cancer death rate and other health effects in three areaa west of the Three Mfle Island Nuclear Generating Station. A case was drawn, with supporting affidavits, that there were high doses of radiations delivered to the environ =ent during the early days of the accident. A. botanist, with expertise in the effects of ionizing radiation on plants, provided an affidavit which stated that, after careful examinati'on of a number of specimens of flera gathered in the areas west of TMI, 'the abnormalities observed could be caused by high-dose beta radiation for a twenty-four hour period.

On Dect:bar 13, 1981, the Com=ission issued an order, CLI-Si-22, denying the Aamodt motion. The Cocmission found that "the Ascedts had not presented sufficient reliable information to show that previous, rore comprehensive and scientific surveys of T)2-2 accident radiation releases are erroneous." Commissioners Asselstine and Bernthal disapproved ef the order.

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Cn Dece=ber 20,19Ei, the Aamodts filed for an extension cf time, until January 15, 1984, to appeal the Commission's decision under 10 CFI Part 2.77I.

!!owever, by letter of Lecerber 28, 1984, Martin G. Malsch, Deputy General Counsel, denied the request on the grounds that the Commission's decisien 2/

was a " quasi-enferecment" actionI This characterization of the Cennissien's decision te:h the Aamedts by surprise. ,

subsequently, on January 2, 1954, in a telephone eenversation with Mr. Msisch, he stated his position that the Co==ission had dealt " infernally" with the Aar:dt motion as an enforcement petition, thus his estegori:stion 1/ Attachrt t 1

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r of the Commission decision as " quasi-enforcement". Since enforcement decisions are final, Mr. Malsch believed that a " quasi-enforcement" decision was final, also.

Mr. Malsch suggested that the Aamodes could seek relief from the Commission's decision by unending their petition of June 21, 1984 or by filing a new peition for an enforcement action by the NRC Staff.

Nowhere in 10CFR Part 2, the rules of practice for domestic licensing proceedings, is a " quasi-enforcement" decision discussed.

There is, therefore, no legal basis to proceed as Mr. Malsch sug8ested.

There is, however, legal basis for the Aamodts to proceed under the rules generally applicable to motions made by parties to a proceeding, 10CFR2.700. The Aamodts, therefore, refer the Commission to their motion of December 21, 1984 for an extension to file t,he present motion for reconsideration of Order CLI-84-22.

Further evidence of the correctness of the path of appeal the Aamodes have chosen is-the filing of the order in the docket of the Restart Proceeding.

Indeed, counsel to the Commission, Irwin Rothchild III, informed the Aamodts the day following the Commission's decision, in a telephone call instituted by Marjorie Aamodt, that a motion for reconsideration was the proper avenue of appeal.

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l Further, the Aamodes find that a motion for a reopening of the public hearings on the restart of Unit 1 is in order. The health issues raised in their motion of June 21, 1984 must be aired, fully and fairly. The health issues

and l / new information concerning the licensee's outright lie to the Pennsylvania l

i Bureau of Radiation Protection concerning the dispatch of survey teams during the early hours of the accident raise concerns which impact on every aspect L

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considered in the Restart Proceeding.

The cancer mortality data presented as a first draft in the Aamodt motion of June 21, 1984 have been verified.by death certificates provided by the Pennsylvania State Health Department and use of school district surveys and tax maps to determine the tota 1 population in the areas surveyed for health effects. A death rate seven times that expected in the areas surveyed has been established.

There is new information concerning the' licensee's deception in that describing its radiation surveillance / supports the allegations in the Aamodt motion of June 21, 1984 that the radiation records (survey and in-plant) and the stack filters were hidden or destroyed by licensee rather than lost.

It is the prime responsibility of the Commission to allow this be information to / examined fairly and openly before the Commission makes its decision on restart of THI-Unit 1, unless than the Commisef oi is . satisfied that the informatica already available moves it to a denial of the license.

The Commission has responsibility for the health and safety of the public.

An enforcement action, outside the Restart Proceeding, is unacceptable, since it would place the matter with the NRC Staff for resolution and decision.

The NRC Staff cannot be trusted to act fairly in this matter. In fact, the ,

Aamodts have filed a complaint with the Department of Justice concerning the Staff criminal actions regarding the Center for Disease Control review of the Aamodt health data. The NRC Staf f altered the copy of the Aamodt motion sent to the " Center" by removing pages and changing an affidavit.

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'. 4 2.0 BASES FOR COMMISSION RECONSIDERATION OF CLI-84-22 2.1 Significant New Information 2.11 The assertion, made in the Aamodt motion of June 21, 1984, of an elevated _ cancer mortality rate has been verified.

Death certificates

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were obtained f, rom the Pennsylvania Department of Health. The popula'. ion for the areas surveyed was checked by use of the West Shore School District survey, conducted at the approximate time of the citizens' health survey, and tax maps. The second draf t of the health data, provided as -

Attachment 3, provides this information in detail. The bottom line is that there is a cancer mortality rate in the areas surveyed west of the Three Mile Island Nuclear Generating Station of 1,097/100,000.

Using base data appropriate for the areas, the cancer mortality rate is ,

7.13 times that expected. This statistic was checked for confidence level (over 95%) for size of sample.

2.12 Licensee personnel lied to the Commonwealth of Pennsylvania personnel at the Bureau of Radiation Protection on the morning of March 28, 1979. Af ter the Commonwealth had been warned of projected releases of 10 R/hr over Goldsborough, TMI personnel discounted this information by claiming, contrary to the fact, that surveillance teams -

had been dispatched and had verified that a significant release had not occurred. This information came to our attention when it was provided as the testimony of a Mr. James Gamble, a former NRC investigator, in the Remanded hearing on the Dieckamp mailgram. This information is provided in Attachment 4

gWe are not at liberty to supply the death certificates because of the need to protect confidentiality. The Commission can obtain copies of the certificates from Dr. George K. Tokuhata, chief epidemiologist in the Pennsylvania Department of Health, who has had these certificates in his possession for some time.

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Although the NRC Staff knew about this blatant lie since ene early investigations of the accident in 1979, the infor=ation had been kept out of the Restart Proceeding. The Commonwealth of Pennsylvania and the licensee cooperated in this deception. CPU management must clarify its position in this matter, particularly in view of claims of lost records and filters from the early hours of the accident when this deception occurred and the matter of serious health effects in the very direction of the falsely-disclaimed high radiation releases.

2.2 Gross Errors 2.21 The Commission made a gross error in depending on information that it asked the NRC Staff to provide concerning the status of dose assessments of the radiation dose to the public as a result of the THI-2 accident.

(Chilk Memorandum, August 27, 1984) This report with its accompanying bibliography (provided as Attachment 5) was not a fair representation of the bibliography, for instance the views expressed in References

1. 23, 32, 37, 43, 46, 50, 54, 61 and 73 which differed from the " official" position that there was a negligible dose to the public were not presented.

Further, the report did not come to terms with the most timely and comprehensive review of dose assessment issued by the Three Mile Island ,

Public Health Fund on August 15, 1984. The " official" position presented in the Staff's report is severely challenged in the rund's report by

" windows" in dose assessment which Dr. Jan Beyea, tha chief investigator, has discovered. The areas NNW and SW of Three Mile Island, where the Aamodts found a cancer mortality rate seven times that expected lay in those '.' windows".

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2.22 The Co==ission made a gross error where it depended (CLI-84-22, page 3) on a letter from the Center for Disease Control from Dr. Glyn Caldwell to Dr. William Mills of NRC, dated September 7,1984 to find that the "Aamodts had not presented convincing evidence of increased cancer incidence, cancer

, mortality, or adverse pregnancy outcomes in TMI-1 area residents related to the TMI-2 accident." The Caldwell critique is shallow and biased and can be presumed to have been influenced by the Staff and Dr. George K. Tokuhata of the Penrsylvania Health Department. The intent of the Staff to influence CDC's critique is clearly revealed by ths fact that the NRC removed eleven pa es and altered an affidavit in the copy of the Aamodt motion sent to CDC.

Although this attempt was foiled by the provision of a cocplete copy by Dr. Tokuhata, this copy was accompanied by a letter which has been described as denegrating of the Aamodts and which the Commission's offices, contrary to law, have failed to provide to ps. An analysis of the CDC critique is provided in Appendix A to this motion.

2.23 The commission made a gross error in allowing ex-parte com=unication with the Staff and the Commonwealth of Pennsylvania and by not providing is the Aamodts with these communications. This/ contrary to NRC rules (10CFR2.780) which forbid ex-parte communications prior to a Commission decision.

These included the CDC critique and the Tokuhata letter. - -

2.24 The Coc=ission made a gross error in accepting the " official" position that there was a negligible dose to the public. The inadequacies of the official studies are clearly demonstrated in the discussion of this cocion and an attached Appendix B. The Three Mile Island Accident, Use of Photographic Film for Dose Assessment.

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's 3.0 BASES FOR REOPENING THE HEARING 3.1 The significant new information provided in Section 2 of this document impacts on the management, emergency planning, health and psychological stress issues of the Restart Proceeding. A reopening is in order, as provided by the NRC rules and regulations 10 CFR 2.503. The health information is significant _new information. Licensee's criminal behavior, described in Section 2.12 of this docum'ent, which put the public at risk, is significant information that is new to the Restart Proceeding.

The Restart Proceeding has been.a long one, however the interests of the public cannot be served if the Commission does not extend it to hear

the significant new information presented in this document. The Commission,

! as presently organized, has as its sole responsibility the protection of health and safety of the public. Whether or not the Unit 1 plant is ready to be operated is not a legitimate consideration in ruling on our motion for a reopening.

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. 4.0 DISCUSSION 4.1 1The Commission's Conclusions Concerning Validity of Aamodt Study The Commission concluded that

,a . "the Aamodt's informal survey is based entirely on recollections and opinions and has no scientific basis",

b. " based on the available information the Commission agrees with the staff and licensee that the Aamodts have not presented sufficient reliable information to show that previous, more comprehensive and scientific surveys of the TMI-2 aecident releases are erroneous" and

c. "CDC concluded that the Aamodts had not presented convincing evidence of increased cancer incidence, mortality or adverse pregnancy outcomes in residents related to the TMI-2 accident." ,

4.2 ' Deficiencies in the Commission's Conclusions 4.21 Previous Scientific Surveys As the Commission notes in its order, the official " projected number of excess fatal cancers due to the accident that could occur over the remaining lifetime of the population within 50 miles of THI-2 is approximately one."

The Aamodt study demonstrated an increase of 16 fatal cancers over the expected number (3) in a four year period.within a sample population .of .

E only 433 persons. Obviously, the Commission did not believe the Aamodt numbers.

l The only attempt made by the Com=ission to verify the Aamodt data 1

was to send an expurgated copy of their motion to CDC for comment.

CDC also made no effort to contact the Aa'modts and also made no attempt to 2/

verify the numbers. On the other hand, Judge Sylvia Rambo of the Middle District Court, Harrisburg, Pennsylvania, who oversees the activities I

L 2/ See Appendix A , Critique of Center for Disease Control (CDC) Resp:nse te Aamodt Study .

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o 9 of the Three Mile Island Public Health Fund ("the Fund"), sent the Aanodt study to the Fund for verification. "The Fund" sent representatives to meet with the Aamodts. "The Fund" did then obtain Seath certificates, all of which noted cancer as the cause of death for 58 of the 20 cancer deaths reported in the Aamodt motion. Difficulty was encountered in obtaining the 19th death certificate, but it is expected shortly. A 20th cancer death was discovered during this followup and the death certificate obtained. "The Fund" also verified the sample population size. . The Aamodts were priveleged to the verification since their participation was needed.

Clearly, the information presented in the Aamodt motion to the Commission was correct and did successfully challenge the " previous, more comprehensive scientific surveys."

This should have come as no surprise to the Commission in view of the

' widely known inadequacies of these previous studies. The only " scientific" aspect to these studies is the sophisticated analytical techniques employed.

They are all based on inadequate and, in some cases, even on non-existent data -- a procedure that can hardly yield a " scientific" estimate of dose assessment.

All actual vent stack data is missin's for the first 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of the

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accident and, due to missing labels, unusable for the next 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br />. ,

To compensate for this deficiency, releases were variously estimated at 0 and proportional to data from monitors in feeders to the vent stack in the fuel handling and auxiliary building ventilation systems. It was 3/ This point is of particular significance in light of the fact that it is

, now generally believed that the bulk of the core damage occurred in the early hours of the accident. (See " Evaluation of Carbons Exposed to the Three Mile Island Accident", Deitz, Romans & Bellamy - 16th DOE Annual Air Cleaning Conference.)

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,, uniformly assumed that there were no un=onitored routes to the outside.

In 1982 it was discovered that a bypass existed around the filters between the containment building and the vent stack. The releif tank vent header bypassed the fuel handling and auxiliary building cartridge monitors.

Numerous other real and potential leakage paths existed, some of which one can be sure have not yet been located, that bypass the vent stack completely.

All of these unmonitored release pathways were essentially ignored in the

" scientific" studies.

Several. other, equally flawed, approaches were made to make dose assessments. TLD data was used. Until March 31, four days after the initiation of the accident, when the NRC placed TLDs at 37 locations around the plant, only 20 Met Ed TLDs were in place, yielding a situation where 3 sectors had no dosimeters and 7 had only one. Clearly serious

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windows existed where radiation could have passed undetected. Further, even this limited data was eventually laundered. The Ad Hoc Dose Assessment group discarded reading s. at 9.6 and 13 ciles in the northwest direction which have the greatest effect on dose estimate.-S/ (Those high readings are referred to in the House Committee on Science and Technology hearing, June 13, 1979, as the " Northwest Anomoly".) No spurious low points were discarded. It should be noted that some of the highest ,

measurements of iodine in milk were recorded in the northwest direction.

4/ At a distance of 1000 meters, at 1 m/s, an angglar variation frot the centerline of the plume of only 9 can cause a 10- reduction TLD reading.

5/ Kemeney Commission " Report of the Task Group on Health Physics and Dosimetry", October 31, 1979, p3, 124-127. Two groups in the WNW direction, one group in the NW direction.

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, The three major studies attempting to correlate the amount of iodine in milk appear to be wildly inconsistent. This should have come as a surprise to noone. Among the inelegant assumptions made by two of the investigating groups was that 10% of the cows' diet came from grazing -

when in fact there was not enough grass on the ground to provide 1% of a

' cow's diet on March 28. This error in " opinion" yielded an error in calculation of a factor of about 180. Beyond this, the researchers could not agree whether iodine vapor or 5 micron iodine particles were more appropriate for calcuation nor whether or not the actual iodine ingested was any part in organic form.

It appears that a good case can be made to support a position that

" scientific" when used in connection with dose assessment is applicable 1

only to the artform of sophisticated analysis, certainly not the substance 6/

of the study. With the possible exception of noble gases and krypton, nobody knows how much of what got out during the early days of the accident -

which is when the great bulk of the radionuclides escaped. In terms of their ability to relate data to chemical or physical parameters, the " previous, more comprehensive and scientific surveys" were scientific failures. Their single redeeming merit is to provide a lower limit on an estimate of actual population doses. , ,

4.22 The Aamodt Study i

By contrast, the "unscienti fic" Aamodt study (which admittedly lacked the analysis techniques of the " scientific" art form) accurately determined that the cancer mortality rate in three elevated areas west of the Susquehanna River was more than 7 times the statistically expected value and that this study population lay in the path of releases of radioactive emmissions from 6/ See Appendix B - Use of Photographic Film for Dose Assesscent

s TMI-2 within the ti=e interval that the largest and unmeasured releases occurred. The " unscientific" Aamodt study also provided simple concise and reliable affidavits by individuals which described their physical i

symptoms which could reasonably,be linked to radiation exposure. It

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.also provided valid descriptions of plant abnormalities observed in the study area. The actual plant specimens were examined by a leading botanist , an expert in radiation effect on flora, who provided an affidavit which was included in the study and which stated that the observed plant effects could be the result of emissions associated with the accident at TMI-2.

This study embodied the epitome of scientific method. It made accurate observations and provided a reasonable hypothesis to explain these observations. As in the case of all human endeavor, including official scientific inquiry, opinion and recollection play an important part. The opinions and recollections used in the Aamodt study stand l

unchallenged. The cancer mortality rate is 7 times that expected. The plants do show abnormal growth patterms that can be attributed to radiation

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e f fects . The individuals who provided affidavits relating to health ef fects 4

did experience these effects, and these effects can be linked to radiation exposure. Releases of radioactive materials of unknown quantity and composition did pass over the study areas in the early days of the accident

'when the individuals did experience effects which can be linked to radiation.

The Aamodt study responded to these facts in a rational, responsible, scientific manner. It simply called for the Commission to make the l

verification, which has now been done, and to determine the impact of this f

finding on a judgement of TMI management integrity, i. e...whether or not licensee had intentionally destroyed or withheld relevant data to cause high releases to be undetected.

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13 4.23 The CDC Response This topic is covered in Appendix A . We would only note here that l the NRC Staff sent CDC a copy of the Aamodt motion in which eleven pages were missing and an affidavit altered. CDC took hardly more than a week to respond and did not contact the Aamodts. .

4.3 The Commission Has Erred The Commission has erred in its order CLI-84-22 on five counts:

1. Its denegration of the Aamodt study. The study was valid, its opinions and recollections demonstrably correct and its method was clearly " scientific".

2. Its conclusion that " previous, more comprehensive and scientific surveys are (not) erroneous" is unsupportable. These surveys are demonstrably erroneous.

3. Reliance on CDC's opinion that the Aamodts have not presented convincing evidence of increased cancer mortalities is unjustified.

sua sponte

4. On the basis of (1 - 3) above, the Commission should have/ reopened l a hearing of these matters in the Restart Proceeding.

I S. By denying further inquiry into the cause of health effects l

! described in the Aamodt motion, the Commission has failed in its ' responsibility to assure public health and safety. The Aamodt motion strongly suggests a real and present danger to the health of residents in the study areas.

Where 19 cancer mortalities have been observed in the four years since the accident, 26 individuals with tumor / cancer affliction during the same period 7/

have been found, suggesting an even higher cancer mortality rate in the future.

l It is the clear responsibility of the Commission to determine whether or not

-7/ This number increased from 19 in the followup with families where a tu=or/ cancer had been reported. (Folicwup was to gain access to medical records.)

o these ef fects are the result of ti e accident at TMI-2 and, if this proves to be the case, take those actions which will mitigate future health effects.

The Commission can no longer rely on post-accident studies, cursory 129 soil tests by EPA (which has not yet measured for 1 in the TNa environs)

'or the self-serving opinions of the licensee and the staff. It has the clear responsibility to determine just exactly what did get out of TMI-2 early in the accident.and, when it gets the answer, take appropriate action.

It appears that the people around TMI were the true " dosimeters". This contention must be examined in a hearing. The matter affects every aspect of the Commission's restart decision.

4.0 MOTIONS 4.1 The Commission is motioned to reconsider its decision CLI-84-22 in view of the gross errors it has made in depending on false information provided by the NRC Staff concerning the status of radiation dose assessments, and the shallow and biased critique of the Aamodt health data by the Center for Disease Control. The decision is predicated on the assu=ption that there was a negligible radiation dose to the public, an assumption which has been severely undermined by comprehensive i ' ~

review of Dr. Jan Beyea and an analysis provided with this motion.

An investigation of the health problems in the population around Three l Mile Island must be conducted expeditiously and openly. The choice of I

an epidemiologist or appropriate organization must be made independently l of the Staff. Opportunity for public access to the investigators must be provided.

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1. 4.2 The Co=ission is motioned to open a hearing to consider the impact of the signifi. cant new verified information concerning a cancer mortality rate 7 times that expected in areas north north west and south southwest of TM1-Unit 1 anti the indesputable evidence of CPU's deliberate deception concerning radiation survie11ance. *The collaboration of the Commonwealth of Pennsylvania and the NRC Staff in withholding the information of GPU's deception is a matter which impacts on all issues concerning restart of Unit 1.

Respe tfully ub=itted' i /

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n O. Aamo't d

$b] LL Marjorib M. Aamodt January 15, 1985

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• • UNITED STATES OF A': ERICA  ; ~. . ' l STCLEAR REGULATORY Cor:ISSION 1 BEFORE THE CO>S!ISSIONERS:

Nunzio J. Palladino, Chairman / ' ,i Thomas M. Roberts .-

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. k' James K. Asselstine ,

Frederick M. Bernthal <\ .

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Lando W. Zech, Jr. \')'-

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In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

)

AAMODT MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR RECONSIDERATION OF ORDER CLI-84-22 The Aamodts request an extension of time until January 15, 1985 to file a motion for the Commission's reconsideration of CLI-84-22, served December 13, 1984. The Aamodts cannot file a motion for reconsideration within the ten days provided by NRC rules and regulations because of prior plans.

Respectfully subr.itted,

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tarjorip M. Aamodt - -

December 20, 1984

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1. c, UNITED STATES

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E NUCLE AR REGULATORY COMMISSION WASHINGTON. D. C 20555

't h' u p . l December 28, 1984 Ms. Marjorie M. Aamodt R.D. #5 Coatesville, PA 19320

Dear Ms. Aamodt:

I am responding to your motion for an extension of time to file a motion for reconsideration of CLI-84-22. The Commission's regulations do not provide for filing requests for reconsideration of quasi-enforcement decisions such as CLI-84-22.

However, should you have new information which you wish to bring to the Commission's attention, you may file a new request or an amended petition.

Sincerely, n4 -

l . T Martin G. Malsch

. Deputy General Counsel cc: TMI-l Service List - -

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THE THREE MILE ISLAND ACCIDENT AN INVESTIGATION OF THE EFFECT ON THE HEALTH OF RESIDE!'T5 AND FLORA IN THREE AREAS NNW AND SW OF TMI BY Marjorie M. Aamodt Principal Investigator O

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Foreword The author is appreciated of the investigative and other efforts of Francine. Taylor and Mary Osborn, without whose centinuing and devoted ~

help this analysis of the citizen's health study would not have possible.

Health Fund to The parallel work of the Three Mile Island Pabli:

4 verify the cancer mortalities and their provision of this informat on l-has been greatly appreciated.

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1.0 ABSTRACT Data collected from interviews with residents in three areas which were in the path of radioactive releases from the Three Mile Island accident demonstrate that cancer mortalities in these areas during the post-accident years 1980 through 1984 is seven times greater than would be expected.

Interviews with the residents in these areas have provided ' horror' tales of ef fects that are remarkedly similar to those caused by exposures to five to one-hundred rems of ionizing radiation.

Analysis of flora growth abnormalities gathered in the same areas geographically led an expert to conclude that these abnormalities could have been induced by radioactive fallout from the Three Mile Island accident.

Although residents have attempted to raise the issue of serious ,

health ef fects in animals and people, no of ficial agency has responded by undertaking a bonafide investigation.

2.0 INTRODUCTION

The official publicly-stated opinion is that radiation releases at the time of the Three Mile Island accident were negligible. This opinion has, however, been challenged by a number of studies.

The most co=prehensive of these is a review of all dose assessment studies by Dr. Jan Beyea under the auspices of the Three Mile Island Public Health Fund.

On Friday, March 30, 1979, three days into the accident, measurements of 1200 millirems were made directly over the plant stacks with helicopters.

This demonstrated the presence of unheard-of acounts of radiation outside the plant. However, the measurements taken from the helicopters were grossly b

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optimistic. The helicopter blades forced the plume away from the measuring instrument.

No dosimetry was on the ground in the areas that were surveyed for health effects. The effects that the people experienced can serve as a more reliable measure of radiation dose than extrapolations from plant releases and distant meters. The flora in the area can also provide that information. In fact, the clue to the kinds of radioactive material released may still reside in the trees and soil.

Following is a summary of the results of surveying a population of approximately 450 people in areas where radioactive plumes passed in the early days of the Three Mile Island accident.

3.0 THE HEALTH SURVEY 3.1 METHOD A group of women and men, several of whom had expertise in conducting surveys, went from door-to. door. An interview for=, organized on the basis of information provided by Dr. Carl Johnson of Denver, Colorado was used. (See Attachment 1.)

Two areas (No. I and 2) were selected because information frem other investigators l/ had identified a high frequency of reports of erythema and metallic taste by the residents. A third area was chosen because it, like the other two areas, was at a high elevation with an. unobstructed view of the Three Mile Island nuclear plants. Figure 1 summarizes the demographic characteristics of these areas.

• The primary interviewers were Francine Taylor, Norma Ritterspach, Jane Lee and Marjorie Aamodt. Assisting were Joyce Corradi, Linda Barash, Sally Stephensen, Brenda Witmer, Marie Inslee, Paula Kinney, Susan Folta, Helen Hocker, Mary Osborn, Er=a Weaver, Cory Folta and Austin Ritterspach.

l' Eileen and Mitsuru Katagiri, wc:k unpublished

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3 FIGURE 1 - DEMOGRAPHIC CHARACTERISTICS OF AREAS SURVEYED Area Direction from TMI Distance Elevation Above Sealevel 1 West Northwest 4 -6mi. 600-750' 2 Southwest , 3hmi. 650' 3 West Northwest 8mi. 900' Almost every household was willing to provide the information solicited. There were no refusals in Area 1, four in Area 2 and 2 in Area 3. The interviewers represented the=selves as a group of citizens that were interested in health problems.

In view of the pioneering effort the survey represented, several excursions were made to interview residents outside of the survey areas because their unique experiences came to the interviewers' attention.

These "outsioe" interviews were helpful in drawing conclusions, however they were not added into the survey data.

While the questionnaire did 'suggest' symptoms, the interviewers i

found, without exception, that this did no more than remind the participant.

Al". interviewers were of the opinion that the residents were conservative in their provision of information and that what was obtained was less than actually existed. For instance, a woman with an obvious lump in her arm did not mention it until the interviewer directly questioned her about it.

The reluctance to report diagnoses of tumors or cancers in living persons, possibly because of associated stigma, was apparent when, on followup an additional six tumor / cancer diagnoses, existing at the tice of the survey, vere finally revealed.

i 0 3.2 RESULTS OF THE SURVEY The survey produced the following significant information:

a. a cancer mortality rate for the. combined area seven tiras greater than would be expected for the population surveyed,

b. a large number of tumors and cancers in living persons that were diagnosed in the period 1979 through 1984, after the Three Mile Island accident and none that were diagnosed prior to this time,

c. other health effects including anemias.and skin rashes which were diagnosed / experienced for the first time after the Three Mile Island accident,

d. eleven birthing abnormalities in the nineteen pregnancies occuring from 1979 through 1984,

e. unexplained medical phenomena of collapsed or ruptured cajor organs occurring in four residents and a fifth person residing outside the areas surveyed 'but in .a north northwest direction about 10 miles frem TMI,

f. first-hand accounts by residents of their experiences on March 28, 29, 30 and April 2, 1979, the early days of the Three Mile Island accident.

3.21 CANCER MCRTALITY RATE Figure 2 presents the cancer mortality rate analysis. The esticated

, numbers of persons in all households (the population) for the areas surveyed was verified by the West Shore School District survey conducted about the same time and tax maps. The prior estimate of 457 persons was lowered to 433.

Eighteen of the twenty cancer deaths reported were verified by death certificates obtained fro = the Pennsylvania Health Department. Two reported deaths were dropped; one (cancer) occurred before the accident (1978) and the other was

2-optimistic. The helicopter blades forced the plume away from the measuring instrument.

No dosimetry was on the ground in the areas that were surveyed for health effects. The effects that the people experienced can serve as, a more reliable measure of radiation dose than extrapolations from plant releases and distant meters. The flora in the area can also provide that information. In fact, the clue to the kinds of radioactive material released may still reside in the trees and soil.

Following is a summary of the results of surveying a population of approximately 450 people in areas where radioactive plumes passed in the early days of the Three Mile Island accident.

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3.0 THE HEALTH SURVEY

, 3.1 METHOD A group of women and men, several of whom had expertise in conducting surveys, went from door-to-door. An interview form, organized on the basis of inforeation provided by Dr. Carl Johnson of Denver, Colorado was used. (See Attachment 1.)

Two areas (No. 1 and 2) were selected because information frqm o,ther ,

investigators 1/ nad identified a high frequency of reports of erythema and metallic taste by'the residents. A third area was chosen because it, like the other two areas, was at a high elevation with an. unobstructed view of the Three Mile Island nuclear plants. Figure 1 sum =arizes the de=ographic characteristics of these areas.

• The primary interviewers were Francine Taylor, Norma Ritterspach, Jane Lee and Marjorie Aamodt. Assisting were Joyce Corradi, Linda Barash, Sally Stephenson, Brenda Witmer, Marie Inslee, Paula Kinney, Susan Folta, Helen Hocker, Mary Osborn, Er=a Weaver, Cory Folta and Austin Ritterspach. .

1 ' Eileen and Mitsuru Katagiri, work unp;tlished

3 FIGURE 1 - DEMOGRAPHIC CHARACTERISTICS OF AREAS SURVEYED Area Direction from TMI Distance Elevation Above Sealevel 1 West Northwest ag.6mi. 600-750' 2 Southwest 3 mi. 650' ,

3 West Northwest 8mi. 900' Almost every household was willing to provide the information solicited. There were no refusals in Area 1, four in Area 2 and 2 in Area 3. The interviewers represented themselves as a group of citizens that were interested in health problems.

In view of the pioneering effort the survey represented, several excursi.'ns were made to interview residents outside of the survey areas because their unique experiences came to the interviewers' attention.

7.

These "outside" interviews were helpful in drawing conclusions, however they were not added into the survey data.

While the questionnaire did 'suggest' symptoms, the interviewers found, without exception, that this did no more than remind the participant.

All interviewers were.of the opinion that the residents were conservative in their provision of information and that what was obtained was less than actually existed. For instance, a woman with an obvious lump in her arm did not mention it until the interviewer directly questioned her about it.

The reluctance to renort diagnoses of tumors or cancers in living persens, possibly because of associated stigma, was apparent when, on followup an additional six tumor / car.cer diagnoses, existing at the time of the survey, were finally revealed.

l l

3.2 RESULTS OF THE SURVEY The survey produced the following significant information:

a. a cancer mortality rate for the_ combined area seven times greater than would be expected for the population surveyed,

b. a large number of tumors and cancers in living persons that were diagnosed in the period 1979 through 1984, after the Three Mile Island accident and none that were diagnosed prior to this time,

c. other health ef fects including anemias and skin rashes which were diagnosed / experienced for the first time af ter the Three Mile

. Island accident,

d. eleven birthing abnormalities in the nineteen pregnancies occuring from 1979 through 1984,

e. unexplained medical phenomena of collap' sed or ruptured major organs occurring in four residents and a fifth person residing outside the areas surveyed ~but in .a north northwest direction about 10 miles from TMI,

f. first-hand accounts by residents of their experiences on March 28, 29, 30 and April 2, 1979, the early days of the Three Mile Island accident.

3.21 CANCER MCRTALITY RATE Figure 2 presents the cancer mortality rate analysis. The estimated

, numbers of persons in all households (the population) for the areas surveyed was verified by the West Shore School District survey conducted about the same time and tax maps. The prior estimate of 457 persons was lowered to 433.

Eichteen of the twenty cancer deaths reported were verified by death certificates obtained fro = the Pennsylvania Health Department. Twe reported deaths were dropped; one (cancer) occurred before the accident (1975) and the other was e

l

. not attributed to cancer on the death certificate. (This latter one =ay be added in to the data if a check with the attending physician proviQes evidence that cancer was a cont,ributing cause of death.) One cancer death certificate was delayed because the place of death was a hospital and not the residence.

A cancer death, not obtained in the survey (noone was at home), was discovered in the followup, and the death certificate was obtained. Thus, twenty cancer deaths have been verified as occurring in the areas surveyed during the post-TMI-2 accident period.

FIGt:RE 2 - CANCER MORTALITY RATE ANALYSIS FOR THREE AREAS WEST OF TMI Area 1 3 2 All No. of Households 37 15 87 139 No. of Households Contacted 34 13 53 100

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Population of Area 111 54 278 433 Cancer Mortalities 1979 - 1984 7 3 10 20 Cancer Mortalities 1980 - 1984 7 3 9 19 Cancer Mortality Rate 1980 - 1984 Per 100,000 Population 1,097 Ratio of Cancer Mortality Rate for 1980-1984 Over Expected 7.13

In figuring the cancer mortality rate, the single death for the year of the accident was dropped, so that the post-accident period considered are the calendar years 1980 through 1984 The baseline datum was derived as appropriate for the rural areas where the survey was conducted. The rationale for this figure, 153.4 cancer deaths per 100,000 population, is provided as Appendix A.

The cancer death rate for the areas surveyed is 1,097/100,000 for the years 1980 through 1984. This is 7.13 times greater than the expected cancer death rate (2.6 exoected, 19 found). The population base was large enough 4 ,

, , , , - - .,-e----.----.w., -ee-n-, ,,w.- r-~-- .-,,-nv -.,,,m---,--..~.e- - - - - - - +,n . -. - . - -

.. .e.

to provide a 95% level of confidence in the stastical analysis.

Figure 3 lists cancer deaths chronologically, providing year of death and quarter, age, sex and diagnosis on death certificate except in case #13 where the death certificate has no; been viewed. For cases #9 and #10, _

the information was provided, telephonically, by the Pennsylvania Health Department and all causes were not obtained. The median age at the time of death was 54 years; sex was equally divided. The dates of diagnosis of the cancers is not yet available. From the interview information, the best determination that can be made is that four cancers were diagnosed prior to the accident: cases #1, #2, #3, #8. The following cases were diagnosed.after the accident: cases #4, #5, #7, #10, #12, #13, #16, #17, #18.

There is no information concerning the other diagnoses.

4 3.22 CANCERS AND TUMORS IN LIVING PERSONS Figure 4 presents the number of cancer / tumors in living persons by area, approximate age, sex and location of affliction. There were 26 cases reported a=eng the surviving persons in the households contacted, or 298 persons. It is not expected that all incidences have been reported; one case was after more than a' dozen contacts with the family. The'reluctdnce was due to concern that this information might ef fect a career if it became known by the e=ployer. There was reluctance where a daughter had lost ovaries.

In that family, case #3, a second daughter is undergoing testing to determine vnether leukemia is the cause of listlessness and high white bloom cell count.

-:"- 3 . -l r:r :_--  : ;r p" ,;r : ,;_v

. YE!.! (C- a rt er) AGl: SD: 1I AfrN!S ,1122:1/.T1. C AUSE , D'!E TO CI AS COMErrES: CT 1 1979 (2) 49 F Rcspiratory fcilurc, Metastatic Carcinoma of breast 2 1950 (2) 72 M Cardiorespiratory failure, Metastatic Carcinoma, Carcinor.a of prostate

.3 1980 (3) 79 F Cardiac arrest, Acute Congestive Heart failure, Dehydration, . . . . Chronic Lymphatic Leukemia

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4 1980 (4) 55 M Carcinematosis, Carcinoma of the colon 5 1980 (4) 30 F Cardio-respiratory failure, Lymphoma of lower spine with eetastasis 6 19S1 (1) 71 F Carcinoca of Cvary with B. . . .. Metastosis and Ascites 7 1981 (2) 63 F Cardiorespiratery Arrest, CVA, Metastatic Carcinera cf of breast 8 1961 (3) 68 M Cardiorespiratory arrest, Metastatic carcinora of prostat of prostate 9 1951 (3) 45 F Melonoma IC 1981 (4) 60 M. Oat cell carcinoma 11 1982 (2) 53 M Cardiorespiratory arrest, Metastatic carcinoma of lung 12 1982 (2) 48 F Malignant Brain Tumor (Astrocytoza) 13 1982 (3) 50 F ' Leukemia 14 1952 (3) 71 F Cardiopu=c:.ary arrest, metastatic cancer, undeter ined etiology 15 19S2 (i) 31 M Multiple Myelo=a 16 1983 (4) 48 M Cardio-respiratory failure, Metastrtic Brain, Cancer, Lung Cancer 17 1984 (1) 46 M Cardicpulrenary Arrest, Lung cancer, COP;,

Esophagcal Eronchial Fistula 65 F Metastatic F211gant Melanoma 1E 19S4 (2) 199 1984 (4) 77 M Hepatic coma, Adeno:arcinera Colon & Liver Met 20 1984 (4) 77 M Hyper bilirubinemia, tumor, probable carcinora h... :f pancreas, obstructive jaundice

_g.

• Tnree persens had r.ct sought redical attention at the tiec of the interview.

These data would suggest a continuing cancer mortality rate far in excess of that expected for this population. Although the date of diagnosis was not obtained, nineteen of the afflicted had certainty that the tumor / cancer was first noticed after 1979. In three cases where the throat was involved (all cancers) and the growth on the vocal cord, all persons were non-smokers.

s -

FIGURE 4 - CANCERS AND TUMORS IN LIVING' PERSONS Area Number Sex / Age Site 1 8 F/ Ovaries ,

F/22 Breast M/38 Muscle, shoulder M/44 Colon M/48 Shoulder, Spine M/25 Vocal cord M/63 Eye, Skin F/65 Breast 3 6 F/40 Liver F/48 Uterus F/32 Breast

=

F/57 Breast F/54 Lymph ,

M/55 Spine 2 12 F/20 Breas t F/43 Breast F/43 Breast F/39 Upper Arm F/40 Uterus F/62 Thyroid M/64 Colon F/67 Blood, Spleen, Skin . .

M/67 Skin, Throat M/70's Throat, Lung M/70's Throat, Jaw F/70's Leg All 26

l 9

3.23 CANCER 7 TUMOR CLL*STERS IN FAMILIES in families The clusters!of cancer deaths and cancers / tutors in the living appears extre=ely unusual and warrants investigation. The clusters suggest a common exposure rather than a genetic predisposition since two cases (#8, #9) were not blood-related. In cases #3 and #6, the most obvious diagnoses for each family group was made within six months. The/ factor that the family clusters had in common was location; the next most common factor was that one, both or all in a cluster were outside during the early days of true the accident. This was/for case #1 (both outside all day), case #2 (one outside),

case #3 (one outside all day), case #7 (both outside all day), case #8 (both outside all day), case #9 (both outside most of day). 'The persons in case #1' were in an open-sided building, but under the cover of a roof; these persons experienced _the plethora of symptoms (metallic taste, errythema, lost of hair, diarrhea, nausea described in Affidavit 1). Some of these symptoms were reported in the other cases, however this information was not uniformly pursued by the interviewers.

FIGURE 5 - CLUSTERS OF CANCER DEATHS AND CANCER /TWOR DIAGNOSES IN FAMILIES Case Relationship in Family Ages Affliction 1 Father, Son 46/25 (Vocal Cords)(Shoulder, Spine) 2 Father, Daughter 44/22 (Colon Cancer)(Breast Cancer) 3 Father, Daughter 38/19 (Muscle Cancer)(Tu= ors Ovaries) 4 Father, Son, Daughter 72/46/40 (Cancer Death).(Cancer Death)(Liver Tucors) 5 Mother, Daughter 57/32 (Ereast Cyst)(Breast Cyst) 6 Mother, Daughter 43/20 (Breast Cyst)(Breast Cyst) 7 Husband, Wife 64/65 (Colon , Cancer)(Cancer Death)

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8 Husband, Wife 67/67 (Skin,T'nroat)(Leuke=ia, Spleen 6 Skin Canca 9 Husband, Wife 770/70 (Throat, Jaw Cancer)(Skin Cancer) 10 Husband, Wife 50/50 (Lucp en Spine)(Cancer Death 1 Leukemia)

3.24 OTHEF. HEAL.TH EFFECTS as first occurring after 1979 Other health ef fects reported in the survey areas /were most notably five cases of anemia, an unquantified number of skin disorders

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of several distinct types and, among nineteen pregnancies between 1979 and 1984, eleven abnormalities. In addition, there appeared to be of a categorr/ traumatic illness which have been designated, for lack of a more scientific determination, as " ruptured / collapsed organs". This to be noticed pheccmena occurred with sufficient frequency (4 in the survey areasy to ani/ afflict per. sons who reported the full range of radiation-related symptoms during the first three days of the TMI-2 accident. (These persons provided affidavits 1 and 6.)

3.241 The eleven birthing abnormalities (nineteen pregnancies) were as follows: one defect, five miscarriages (one with fetus outside womb),

one stillbirth, three non-elective Caesarean Sections, one premature birth.

All occurred since March 1979; the birth defect and pregnancy termination with fetus outside the uterus occurred in 1979. One would expect to see 5*4 birth defects and a 127. spontaneous abortion rate (defined as a pregnancy loss during the first six months of pregnancy). The observed events of these kinds (6) were twice the expected (3.1). The reports of C sections were enumerated to suggest an avenue of inquiry. Dr. George were eliminated from the pregnancy outcoce study of the Pennsylvania

_2/

Health Department. Important data may have been overlooked since a veterinarian, practic.ing on the west shore, noted a fourfold demand in pigs for C sections in 1979. These and other important animal data were 2 / "Three Mile Island (TMI) Nuclear Accident and Pregnancy Outcome",

George K. Tekuhata, Joyce Kim, Jane Bratz, Pennsylvania Health Department

I .

dismissed by the efficial agencies be.ause whele body counts did net indicate 3/

radiation relationship and no ether cause suggested itself7 It appears to be a gross error that caused the animal problems to be handled rather lightly. The attribution of crippling and other deformaties in cattle to the sudden occurrence of a selenium deficiency in the soil is remarkable.

The decrease in symptoms after the addition of selenium to the cattle diet was considered confirmatory whereas there was also a correlation to time the distance in time from the TMI-2 accident, hence decrease in radiation (released from the plant) in the environment.

3.242 The reports of skin problems were remarkable but difficult to greying and loss of hair quantify. They included tingling skin / reoccurring rashes (most frequently on the face and arms), errythema at the time of the accident and a few reports since, sprays of cysts, red spots, " bruise-like" marks, darkened skin,

' sensitivity to the sun, blister on lips and in the mouth, open sores, melanoma and other skin cancer. There were also reports of dogs with blisters on their feet and bellies, and loss of hair. These phenomena have continued-to be experienced but with a decreased incidence since the accident at TMI. These symptoms are remarkably similar to those experienced by victims at Rocky Flats and Hiroshi=a.

3.243 The cases of " ruptured / collapsed" organs are sum =arized in, Figure 6 ,

by year of 9:currence, survey area, sex, age and description of the phenomena provided by the afflicted.

3/NUREG-073E, EPA 600/4-80-049

e All instances of the " phenomena" were in the '- d ir ec t ion o f TMI .

Two cases were in persons who had experiences on March 29 and 30 which appear to be high dose radiation effects. The following effects occurred,

- according to the afflicted, " spontaneously".

FIGURE 6 " COLLAPSED / RUPTURED ORGANS" Area Sex / Age Afflicted's Description Year Occurred 1 M/43* Aortic Valve Ruptured 1981 3 F/19 Lung Collapsed 1980 3 M/53 Spleen Ruptured 1983 3 F/29 Two Arteries to Heart Blocked 1984 (907 and 70*4)

NNW Beyond 1 & '3, Elevated F/55 's** Kidney Collapsed 1983

• Provided Af fidavit 1

• • Provided Affidavit 6 3.3 STATEMENT OF RESIDENTS WHO EXPERIENCED EFFECTS MOST REASONABLY ATTRIBUTED TO EXPOSURE TO HIGH-DOSE RADIATION Affidavits 1 through 7 present first-hand accounts of what appears to be touchdown of plumes from TMI-2 on or near residents in the areas surveyed ,

and three other locations, WNW of TF" iieure 7 su==arizes the experiences by affidavit, location fro: TMI. ' .ex/ age.

l

.* -1:-

There are several common factors : direction from the THE plant; being outside _

There are several common factors. All persons were outside when their experience began (except the dentist who indicated that the door facing to the SE wac probably open). The experiences in the n,,: direction from TMI a111 occurred on the first three days of the accident. There is a commonality of experiences: Metallic taste was mentioned by #1,2,5 and 7. Errythema was mentioned by #1,2, and 6. Burning skin was mentioned by F1,2, and possibly

4. Tearing and/or red eyes was mentioned by #1, 4 Nausea was mentioned by #1,2, and 5. Hair loss was mentioned by #1 and 6. Immediate skin problems were mentioned by 91 and 6.

y - . , . , - . _ , , , ,e.- -

e l

FIGURE 7 -

SUMMARY

OF UNUSUAL EXPEh1ENCES 05 MARCH 25-3C,1979 REPORTED BY RESIDENT 5 NW OF TV1 Affidavit Date Distance Sex / Age Experiences on Date, Subsequently ()  !

l 1 3/29-30 4mi. M/43 Metallic taste; very red face, neck, hands; nauseous, eyes red and burning, felt like

~

- looking through water, lips and nose blistered; throat and chest burning; taste of burning galvanized steel,(severe diarrhea, hair loss on head, ar=s, legs and torso; sore that would not heal; spontaneous collapse of aortic valve.)

in light mist-2 4/2 M/40's Outside in the evening between 6-7; skin burning; face, arms and hands reddened and remained red for about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; metallic taste; nauseous; felt " funny" in head; sav doctor 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later - found symptoms matched radiation induced.

3 3/30 F/40's Outside on porch for few minutes in afternoon; heard " rain" in the trees although it was not raining; very still; l

no usual sounds of birds.

4 3/28 M/40's Eyes watering and burning after ten min. valk outside; eyes watered entire night;(problems with eyes: burning, red in appearance; red cark on side of nose, rash on forear=s reccurring.)

5 3/26-29 M/40's Metalish taste; queasy stomach; felt

" funny"; X-ray films fogged (75 approx.)

~ in evening 6 3/30 F/55's Engulfed in wave of heat on' porch /as~ rain cocentarily stopped; face felt tingly; within an hour face and arms pink; following day skin darker pink, itch at front of scalp; two days later hard little lumps appeared en ferehead into hairline; scalp felt prickly and tingly; three weeks later cany gray hairs accross front of hair; hair falling cut; subsequent weeks skin on forearms and neck darkened and scaled; (permanent discoloration of skin on forearms, neck and face; sensitive to sunlight; bruise easily; number of spots on face and chest - yellow centers; sudden loss of kidney function).

7 3/28 F/40 's Metallic s ell and taste, very strong cutsidc at t ar. Net neticed a 5 ar c tside.

l. 0 FJO1ATION EFFECTS ON PL\NTS Affidavit 9 was provided by James E. Gunckel who is a recognized authority on radiation effects in plants. Dr. Gunckel's pioneer research concerning ionizing radiation ef fects on plants was cenducted at the Brookhaven Laboratories and Rutgers University for 34 years. Three papers published by Dr. Gunckel are referenced at Attachment 3.

Dr. Gunckel examined plants and leaves provided by Mary Osborn of Swatara, Pennsylvania. The flora were gathered in the area of her home, NNW of TMI, approximately six miles. Other specimens were provided by ,

a resident from her yard approximately three miles NNW of TMI. A f a r=c r ,

. whose home and farm are located two miles NNW of TMI provided Affidavit 8 which describes the necessary changes in his farming practices since the

~

acc ident . He can no longer grow clover seed, an experience shared by farmers in the area as far as 15 miles from TMI. He mentioned the absence of the bee which pollinates red clover since the time of the TMI accident.

Dr. Gunckel thoroughly examined all specimens brought to him te rule out the effect of insects or disease. He questioned Ms. Osborn concerning the location of the specimens to rule out the effects of roadside spraying and agricultural spraying. There were_two sessions spanning about ten hours that Dr. Gunckel devoted to exa ining specimens. He described the ana=alies as " entirely comparable to those induced by ionizing radiation -- ste faciations, growth stimulation, induction of extra vegetative buds and ste= tumors. He concluded that "it uould have been possible for the types of plant abnormalities observed to have been induced by radioactive fallout on March 2^, 1979." This was the day when 1200 er releases were ceasured at the stack, an indication of large a= cunts of radiation being released frer the p' ant, how2ver net an reliable reasure cf the ameunt since the

e helicopters forced the plu e away from the reasuring devise.

Dr. Gunckel hypothesized the exposure of the plants as beta 32 ~65

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ray exposure from radioisotopes (P , Ca45)

, 2n .

for twenty-four hours. He raised a point about the relative " quality factor" of gamma and beta radiation, which appears to be contrary to what is generally assumed but is incontrovertible on the basis of experimen:1.

he conducted. That is that beta rays are at least at least a

• quality facter of two in plants.

Dr. Gunckel has been provided with descriptions and pictures of dandelion leaves that are 31 inches long that were picked this summer on the property where (Affidavit) I was working on March 28 and 29 of ~

1979 and other flora effects. He believes that these anomalies are evidence of continued impact from radiation other than background.

5.0 DISCUSSION The suggestion that the cancers present in the areas surveyed were initiated by radioactive releases from the TMI accident defies the generally accepted theory cf a period of considerable latency following

-expcsure. We suggest that this theory is not viable in the present case.

k'e believe that the critical exposure was to beta and alpha particulates.

- and that the biological ef fects were si _ Jar to those described by Dr. Gunckel in plants.

s*

The hypotterir cf parti:;1ste e x, c r ;: ( ir r;n crie: , - he rcrid  :'

ex;eriencer on March E, 29. 20 and April :. reported in the affidavite.

The suggestion that these experiences were not unique to the three stud',

areas is provided by the letter of Representative Stephen Reed to the NRC on August 8, 1979, provided as Attachment 2. The days on which these experiences occurred were reported as the same days as those of the persons who reside in the study areas, indicating a more extensive impact than in the study areas, i. e. " hundreds" of calls were received by Rep. Reed.

This number of reports of phenomena which are discrete in kinds --

metallic taste, tearing eyes, diarrhea, skin rashes -- reported by a large number of people cannot be dismissed as hysteria. In fact, the symptoms were experienced before the occurrence or seriousness of the accident was knew .

The fact that the types of experiences re' ported are those commonly associated with radiation exposure and that they occurred at essentially the same time that.there were releases of radiation from TMI-2 of undetermined amounts supports a conclusion that the experiences were radiation-induced.

The flora data also support that conclusion. Ano:clies have been found in other areas indicating that areas of insult are not solely. .

within the study areas.

Since the people and plants appear to have been the dosimeters, best the arcant and kinds cf radiation released could be/deternined fror this infor stien. Acccrding to a verbal communication with Ms. Osborn (cen-ioned abcVe), an NFC autNerity, Dr. Edward Branigan esticated a dose in excess of 100 rems with errythesia. This again supports the

~1 1

< 1

.* .r-particulate th(Ori rinec a dor < in (-xcers cf ::: :< r w: s o oddy) wculd probably have res;1:ed in to e in.cdiate los: of lift. We are not aware of such occurrences.

Tt.e soil sampling that has been done by the agencies was found less than credible because of the uniformity of the reports.- (Beyea Report)

The agencies (NRC, EPA, DER) did sampling of soil and water in the survey areas identified to them on August 30, 1984 and shortly thereafter. Some of the results of this testing have been repcrted and interpreted as being insignificant or due to weapons testing. (Letters from NRC and EPA -

Travers to Aamodt, October 22, 1984 and Kirk to Aarodt, October 31, 1954)

At that time, testing had not been completed; the remainino results have 120

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been promised shortly. None of agencies would agree to test for I as requested. Such a test would allow esticates of I that was released during the accident, a contested issce among experts.

Continued insult from the environment has been rescrted., In Area 1 of the survey, residents continue to experience some of the same symptoms reported as occurring for the first time at the time of the accident.

These experiences appear to be related to tires spent out-of-doors.

We believe that the Pennsylvania Health Depar tment's records may unravel some of the cysteries. There have, however, been dif ficulties

• experienced in ettaining tnese reccrds.

Tns pregnancy dsta 'gatnered in the stud:' would lead to a vastly different conclusion than that done by the 7+.-.sylvania Health Espartment.

The latter's conclusions cf no significant in:rease in pregnancy-related problers was based en the comparison of pregnancies during the accident and after the a::ident. The assu.,-ion is that exposure was instant which does n:t appear to be supportei ti car cenclusions of

radiation remaining in the environment. We are trying, as yet unsuccessfully, to obtain Dr. Tokuhata's raw data. In view of the verification of the cancer mortality data gathered from the interviews, the report of 11 abnormalities in 19 pregnancies in the study areas, wewould not consider the pregnancy outcome a resolved matter. The listing of " disruption of the menstrual cycle" in Representative Reed's letter as a frequently reported symptom would indicate an impact from the accident en the reproductive system.

Despite the drop'in neonatal hypothyroidism in Lancaster County to expected incidence, the explanation of consanguinity among the Amish for the seven-fold greater incidence following the TMI-2 accident has not, as yet, been retracted by Dr. Tokuhata. A more valid hypothesis would appear to be that the Amish pregnant had a higher exposure than other pregnant woman to the releases from the accident because of their sociological practices. Amish women farm with their husbands and were more likely to be outside than other pregnant woren as early in the spring as the accident occurred. The Amish family keeps its own cows and fresh . ilk is consumed.

6.0

SUMMARY

A study of health effects has been conducted with a populat' ion residing at high elevations in areas where the wind blew during the early hcurs of.the accident at TMI-2. This study demonstrates:

1. a seven-fold increase over expected cancer mortality rate,

2. evidence of insult to this population, beginning March 28, 1979, which caused symptoms typical of those expected from high radiation exposure,

3. evidence of plant abnormalities, occurring only since 1979' which are related by a leading expert in radiation effects on flora to the accident 1: TMI-2,

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4. evidence of non-geneticall-2 induced coincidental cancers within household groups exposed to the environment during the early days of the accident,

5. evidence of a doubling of expected human birth abnormalities since the accident, -

6. evidence of an excessive number of tumors within the surviving population, suggesting a continued gross elevation of cancer mortality rate, All of this evidence converges to support a hypothesis that severe radiation effects were experienced by the study population as a direct result of early, heretofor unconsidered early releases from TMI-2 during the accident beginning March 28, 1979.

9 6 6

9

k.

c' AFFKDAVIT 1 On April 24, 1984, I, ,

6 provided the following information in response to a questionnaire presented by Francine Taylor of Lancaster, Pa. and to Marjorie Aamodt in a subsequent interview that same day. I also provided Ms. Aamodt with a letter which was addressed to Governor Thornburgh and is dated November 19, 1981. I never received an answer to this letter. The letter is attached to this affidavit and is to be considered a part of it.

At the time of the TMI acciden , I was living,at 6, not far from my presenc home. ~This area is approximately four miles northwest of THI Concerning my experiences following the accident at TMI: On Thrusday, March 29, 1979, I was working a'1 day with my son in our garage. The garage doors were open. That nigit when I took a shower, my face, neck and hands looked like I was at the seashore and got burned real bad. I felt nauseous. My eyes were red and burning. I felt like I was looking through water. Friday morning when I got out of bed, my lips and nose were blistered, and my throat and inside my chest felt like fire.

It tasted like burning galvanized steel. My son had similar experiences He was 22 years old at the time. On Friday we decided to evacuate. While packing our truck, a township police of ficer, in a closed car, shouted over his loudspeaker system " Bill, don't breath this air Get inside'"

We spent the first night in Mechanicsburg with relatives. We convinced nther family members to go with us and traveled to Front Royal, Va on Saturday. We stayed at a camp ground in Front Royal for about one week During this time I experienced severe diarrhea which caused rectal bleeding We took one of our dogs with us, a German Shepherd,, female. Following our arrival in Virginia, the dog passed only blood from the rectum and 11eed from the nose and mouth. Since I felt that these conditions may have been caused by nervousness due to our flight, I gave her a sedative When we returned home, we went in the garage first and found our male German Shepherd had died. His eyes were milky white. We had provided about 100 lb. of food and 50 gallons of water, however, he had only drunk water, about five gallons. It appeared that he had thrown up some of this water before he died. We had five cats that lived in a box on the back porch. All but one was dead. All cats had milky white eyes. The one living.. cat had one eye that was milky white: skin grew over this eye during the following weeks. This cat lived for about six mgnths after the accident.

She had kittens prior to her death. The kittens were born dead and hairless I should also note that we noted a metallic taste when we entered.our ha ,

home after the evacuation.

My son and I have both experienced hair loss; mine was on my head, arms, legs and torso This hair has regrown. My son lost hair on his arms and torso, which has also regrown. In 1981 a sore developed on my leg.

The sore remained for two years, healing af ter we moved to Florida The ef fected area is still detectable as a faint discoloring. The skin was inflammed, open, and raised; the doctor's diagnosis was uncertain. Also in 1981 my wife, 35EE3, was diagnosed as having paroxysmal tachycardia l and in 1982 as having an underactive thyroid. I have also experienced problems with my heart. Although I had had a slight summer prior to the accident, I had passed a physical required for racing cars. However, b December 1980 I needed to undergo an aortic valve replacement. I was 43 years old at the time.

The spring following the accident, our walnut trees did not produce any leaves, and there were no walnuts. There were no flies or other flying insects until July 1979. There were no birds, squirrels or pheasants

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Th3 cpring following tho accident, our walnut troce did not produto any 1ccvos, end th3ro woro no estruto. Thoro were no flico or other flytag insects until July 1979. There were no birds,

squirrels or pheasants for about a year and one-half fo11owing the j accident. I found a number of dead birds. A number of neighbors -  ;

died of cancer.

In 1933 I felt that I could not continue to live in this neighborhood, so close to the TMI plants. I sold my home and business ,

at considerably less than its appraised value and moved to Florida.

Nowever, we returned this year and are living in a new home at M j g , maar our previous home. We got homesick., 8ty daughter and graadchildren live in this area, as well as other relatives, and l telephone communication with them was not sufficient contact. Bir som left with us for Florida and has stayed there.

i I had been in business la Fairview Township, York County, for twenty-two years,. I operated an automobile sales and service shop.

I was involved in community affairs as a justice of the peace and la politics as a committeeman.

All of the above information was provided volunts'rily, and I I

ettest to its truthfulness.

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AFFIDAVIT 2 De May 5, 1984.,I, m , provided the following information to Marjorie Aamodt at my place of reetdence on 6 i M lty residence is approximately 4-3 miles eeuth west of TMI and is at a high elevation, De Monday evening, April 2,1979, af ter returning from West Virginia l where I had evacuated with my family, I worked outside on my camper from approximately 6 until 7 p. m. My family stayed inside. When my wife j called me in for supper, my skin was burning. My face arms and hands '

were reddened and remained that way for alwar/.2 8wes ,I had a metallic taste.

I felt sauseous. I felt "fummy in the head". I took a shower that evening before going to bed. giace I had a head cold, I went to the doctor's the seat day. I told my doctor about my experiences the following evening. lie read from a book what symptoms are related to radiation exposure. We noted that these symptoms matched what I had esperienced, however the doctor reassured me that nothing had come out of the plant. Concerning the weather conditions on the Monday eventag.

April 2, 1979, I remember that there was a light mist over the area.

l Date sworn

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. AFFIBAVIT 3 I,

provided the following inf,ormation to Marjorie Aamodt in a telephone conversatiam on June 13, 1944. I was ill with the flu at the tias di the TNI accident. I was in bed most of the tias. However, one day, which 4 i believe was Friday, March 30, 1979, I was out of bed and decided to shake out a throw rug. I went out on the porch. It sounded as if it was raining. The sound appeared to be in the trees. I could not,see any rain so I reached out beyond the porch roof to try to feel it. I did not feel any rain on my hands or arms. I was extremely pussted, l I was impressed by the stillness except for the eu.-d of rain. There were no sounds of bLrds or other sounds to which we are secuatoned.

This all seemed very strange, however I was too sick at the time to Pursue the matter further, so I returned to bed. My certainty in datias this event on March 30, 1979 is tied to a telephone call I received later that same day. A neighbor called to tell as that my son had been'taken from his school to Dillsburg because of the TNI accident, and she volunteered to pick him up.

I could never set the experience of the silence and the rain-like sound out of'my mind. Subsequently, several of my friends told me about similar experiences at the same time. One of these friends '

tam I and my sons remained during the accident. We would have ,

chosen to leave, however I am a widow, and.I did not have sufftencient financial resources to leave. .

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AFFIDAVIT 4 ,m On April 28, 1984, at my home, _ , , _ . _ '

4 , I related the following experiences that I had at the time of the accident at TMI. On Wednesday evening, March 28, 1979, unauses of any problems at the TMI plaats, my wife and I were outside "

g in the avesias to take a wait en our street. The walk lasted appresinately ten minutes. That evening, my eyes began to water and burn. My eyes watered throughout the entire night.

In the Yall of 1982, I began to have problems with my eyes. My eyes felt like they were burntag. About three months after this occurred, I decided to see a doctor. At this time the skin around my eyes was irritated and red, and there was a distinct red mark on the innerside of my nose. Although the redness around my eyes has disappeared, the stark on my nose has remained. <

The first doctor appeared unable to help, and since~I was troubled about my eye condition, unique to me during my lifetime, I saw a second doctor. I also hed a rash on my forearme which had some and goes since shortly after March 1979. This cash is ,

particularlynoticeable after showering and in warm weather. Tne .

dermatologist prescribed Fredaisons.

In 1981, my wife g was diagnosed as having fibroid tumors in her uterus. These tumors were large, but wer's successfully removed in September of 1982.

I believe that my skin conditions and possibly my wife's tumors are related to some exposure we may have gotten from the accident at TM1. We were unaware of the problems there or any dangers to ourselves until severai days after the accident. Actually, it was a TMI worker who is a neighbor and who evacuated early on..the first day of the accident who returned on the weekend to warn his*' neighbors to evacuate.

• e MMemeGemeGeeeeeeeeeeemme Dated-----------------------

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AFFIDAVIT 5 On Friday, April 29,1984, I provided the following information to Marjorie Aamodt in my dental office in , located at This information concerned my superiences em Wednesday and Thrveday, March 28 and 29,1979. Da those days, I

' discovered that, the X-ray films La my dental of fice in .

were fogged. This office is located a in a stone building # miles north west of TMI.

The film fossing can be described as alternately light and dask bandias.

across the entire film. Approntmately 75 films were "fossed". These films had been placed in a little container for easy access in the X-ray room.

The I-ray room has an outvall of cinderblock and gypsum board. The film i is #2 oral film, fast D film, 0.2 mr exposure. The machine is marked as 70 KV, 7.5 m. asps, 3/10 sec., for jaw erposure On Friday following.

March 30, 1979 I posted new film outside the butiding each day for sa entire week, however these films were not exposed. On Wednesday and Thrveday, March 28 and 29,1979, I emperienced a metatish taste and

! a queasy stomach. I felt " funny" and empressed this feeling to my receptionist. At that time I had no knowledge of the accident at TNI.

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AFFIDAVIT 6 x,N m provided the following informatis,n to Jane Lee and Marjorie Aamodt on May 11, 1984. I was standing on the front On Friday evening, Harch 30, 1979, It was raining, and the wind r i

peren of my home. My home faces south.

was blowing. All of a . sudden the cat that had been let out begna toI had '

host in a most unusual way.I called the cat by name, however it did act this or any other cat.From the direction of the howling, I could tell that the ,  ;

come home.

cat was under the porch. I went over to the bannister and leaned ,

While standing in this position at the '

over to call the cat again.

east side of the porch, I experienced a most The unusual s of the trees next to the porch, and a wave of heat engulfed me.Then the wind s gust of heat brought the rain over me. I was so startled that I went This all happened in about one minute. I wiped the in, taking the cat, who had by now come up on the porch.My fa'ce felt cat's wet coat and then washed my hands and face.My face again and wiped my tingly. About an hour later, I washedI noticed,that my arms and face wtre j arms and legs with the' towel.

pink. I applied a lotion because my skin felt tingly.

On Saturday morning, my skin was a darker pink, and there was m This was the only part of my scalp itch at the front of my scalp. When I went to church on Sunday, my that was not oovered by a scarf.

friends commented that I looked healthy and sunburned. On this day, hard little lumps, a little bigger than a pinhead appared on my forehead and into the hairline.

On Tuesday, my scalp felt prickly and tingly, so I washed my hair again, shampoeing it three times which is more than IAbout,three custcearily do. (I generally wash my hair once a week.)

weeks later, I noticed that a lot of gray hairs had appeared across the front of my hair. When I washed my hair that week, my comb was I called my full of hair. The next week, the loss of hair increased.

hairdresser M who subsequently applied treatments which he believed would arrest the loss of hair. The hair loss did appear to stop.

The gray hairs have also disappeared, and my ifair is now uniformly brown as it was before the events described. .

In the subsequent weeks, the skin on my forearms and neck turned darker and was scaly.

This condition lasted for several years.

• There is however some permanent discoloration however it not prominent., My forearms were, and continue I try to be, very sensitive toI to avoid sunlight.

the sun, becoming itchy with exposure.

have also noticed that if my arms are injured, the bruise will last longer than was normal for me prior to the events described above.

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A number af cpots hava appeared on my fac3 and chest. Thaco cppe: red cftcr the tiny hard bumps went cway. Six cf theo3 spoco, cr piaples, remain. Some of the pimpias have yellow centers. The size of these pimples appears to have diminished somewhat, and they are l not sensitive, however I an uncomfortable with this condition of my skin, unlike its condition prior to the events desi:ribed above.

Of greatest concern to me presently is the loss of the function ef a kidney. Toward the end of November 1983, I was in renal -

failure. My doctor described my condition as an unusual case. No stated that one of my kidneys had died. I was in Holy Spirit Hospital under the care of Des. Bean and Eaton. I have not fully .

recovered, and I have nc.t been able to resume my customary social and household activities.

I live on a farm with my husband. We were not able to evacuate during the accident, although I wanted to leave, because my husand would not ask anyone else to stay to do his job of caring for the ,

animals. Despite our continual attention to the cattle, wo experienced the first deformed salves ever born on our farm the following spring. The calves' heads hung to one side until they were six months old. Their necks appeared twisted. I also noted that the Norway maple by our home had deformed leaves which were curled at the edsea.

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AFFIVADIT 7, e

I, reside at six and one-half miles north northwest of TMI. This was also my i

residence at the time of the TMI accident as well as that of my l husband, som and daughter. ,

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On the morning of March 28, 1979, my husband was putting his , i tools isto his truck. 'It was six o' clock in the morning when he same  ;

l la to ask me to go out and smell the air. I wondered to myself whether it would be the Hershey chocolate smell or the aroma of Capitel Sakers' bread. This time the air was different. The air smelled like metal. It was overwhelming. I could taste metal in my mouth. It seemed as though as every taste bud in my mouth could sense this metal. We were very puzzled.

Later that morning, at 8 o' clock, my son and I walked my i

daughter to the bus stop. There was no metallic smell in the air.

4 Dete...................

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1, M of M provided tha following

{ infermition to Jens Leo, e neighb:r, cod Marjerto Aamodt et cy 5 home en on Monday, May 7,1934. I provided this informaties voldatar y attest to its truthfulness.  ;

aqr beme is approximately 2 miles from the TMI plants. My house j fossa la that direction and is north west of TMI. I have several trees la sy freatyard. One of these, a maple at the south corner of the yard i

nest to a wooden fence appeared to be affected by the accident at TNI.

H is tree is about .50 years old and is still living, however it has' i undergone considerable changes. About a week after the accident. I '

meticed that the leaves in the center of the tree were turning brown.

The leaves then dropped off leaving a circle of defoliation about twelve

, feet in diameter. The next year the barked dropped of f many branches.

his caused

• these branches to die. About one-fourth of the 11mbs are now gone. The top of the tree, which was the area that was affected after the accident, now has few leaves. Two year trees, one a Esifer and the other a Marvest, both planted in the late 1920's, have died.

d'r4 trees had been good bearing trees prior to the accident, however they all pro 4pcod dwarfed years after the accident. The number of bears decreased also. Since the accident, I can no longer grow clover seed. because the clover yields so few seeds. In 1981,' the test s year I grew clover, there were only 0 -/o seeds per stem, whereas 1.got j about TE- MS eeeds per stem before the accident. This problem has j' affected other farmers in my area, but is not a problem on a farm in this area but at a greater distance from the TMI plants, approximately/2-4'ailes.

'; I attribute

• the decrease in seed production to the digappearance of bumble bees that pollinate clover. Last year we had no apples from our 3 trees.

One apple tree, in the yard, started ' going back' after the accident.

Last year, it only had a couple of leaves, three blossoms and no apples.

The only crop that 'does good' is, potatoes. We have had a number of I

problems with livestock including sows that'did not come into heat. Thess ,

sows were not born on my farm, but were purchased from a farm near here.

I was inside my house on the day of the accident and stayed in most of the time. I have a rash 'back of my ear'and down.on the side of my face' '

ever since the Krypton venting began.

I have Lived in this area all of my life and have farmed since /9s."[. .

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. May llj198h mmm9 I have carefully examined a few specimens of omme plants collected l

shortly after the accident at 1MI and ccespared them with specimens collected i

more recent2y. The curant abnomalities am probably carried forward by induoed chrmosomal aberrations. There wem a rasnber of anmalies entire 2y emparshle to those induced by ionizing radiation - stem fasciatime, growth stimulation, ineactim of extra vegetative buds and sta tumors.

l Most of the stem abnomalities described in the literature, and in my om experience, are ineced by relatively high doses of I or gamma rays extendag over a period of usually 2-3 months. Notable exceptions, however, am similar responses to beta ray exposum fra radoisotopes (P32, 2nU, Cad) and for only 214 hours0.00248 days <br />0.0594 hours <br />3.53836e-4 weeks <br />8.1427e-5 months <br />. In other words, it would have been possible for the types of plant atmoraalities observed to have bestr in&ced by radioactive fallout on March 29, 1979 .

! la escussLag the general biological effects of irradiation, see clari-f1catica may be helpful. In plants, the dose rste (e.g.,. Jar /hr) is mach som japortant than total dose (e.g., ar/yr) in inducing abnormalities. Further, the 8 equality factor # for gassna and beta radiation is not the same as gamerally-assumed. In fact, I have incontrovertible experimental results to show that beta rays are at least a quality factor of two in plants.

I as the world authority on modifications of plant growth and development l

Anduced by ionis2ng radiations, having researched this area for 324 years at 1

the Brookhaven National laboratory and at Rutgers University. The t,hme review papers appended attest to my expertise.

• E James E. Oundel I

. Coco sumber /W

.* ^ ATTACHMENT 01 A VOLU%TARY CQs96Ull!TV 18EALTH SURVEY

.* sesto s Locattens l

8. Isave you been contacted by the pa. Dept. Of Blealth survey em TIL1?An?

J J. Fen 11y sans afilling to participate? yes na j ,

8. Fem &1y memberas gaat 2181M8 SSL E JZ15421M 2/20119 1 (doctor) .

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8 f doesased, when?

• cnset of illness Diagnosis Dr.  ;

l f 4. Current address and phone 30.3 Address en 3/28/1979:

1 j 's . Persons outdoors? 33mg

• 3/28-houra 3/29-houra

• 2/lR-houra l

• • . If vacated the areas yhg 13 Mha&R Mban Aall--khan gain 1Enad V. Did anyone notice (indicate date, time, who)

a. unusual atmospheric conditions D. metallic taste, smell

c. eye irritation, burning

d. skin Kritation, " , reddenina

e. Arritetten of nose, throat. chest

f. esperianos nausea

e. esperience vomittna

h. espersenos diarrhes

a. esperience headaches J. develop hypothyroidism hyperthroadise

k. within 2-4 wks unusual hair loss er color change

1. red spots under skin bleeding guns

m. unusual bleedina 3

n. cancer form treatment doctor

o. Inter was there confirmed (doctor) anomas blood or thyroid disorder g women If pregnant. date of last monstrual period before 3/28/79 Complications with pregnancy? et111 birth miscarriage premature birth Date of birth wt. at birth  ;

health of child since birth caesarean section Date of birth wt. et b&rth health ofchild since birth erib death t fi,Wistory of disorders in f amily tree (leukemia, eeneers, thyread.etc.)

,ld . Antinale , gag =a= in 3/79 inalde/outside alive / dead health arablems b

II. Addittenal comments

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Attachm2nt 2

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Dangerous Properties of ndustrial Materia s Fifth Edition i

. N.IRVING SAX Assisted by: .

l Marilyn C. Stacken/ Robert D. Bruce / William F. Durham/ Benjamin Feiner/

Edward G. Fitagerald/ Joseph J. FitzGerald/ Barbara J. Goldsmith / John H. Harley/

I Robert Herrick/ Richard J. Lewis / James R. Mahoney/ John F. Schmutz/

E. June Thompson / Elizabeth K. Weisburger/ David Gordon Wilson 1

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absorption sfad these dineremoss also am biologscally aismiscant. Alpha panacess are heavy, slow movias,and l , g[ $#. f.'jis M ,i6 expend hir wrgy in a mentiwh shon path. Dey am,1 I. ' l 3 .I therefore, spoken of as showing high specafic soeuatsen, J g IJ s K , 's f g "S 3 y

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ably. Emitters located se a small section of tasses udl w-radiate that small section wry leenvily.

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RADIATION MAZAstOS 131

, Jace a innuderable ellect Their specific inniuts:n hone structur2. Agdeyution, there is us"2nv a raa-t' high cithough not as prest as that tar o radiati:n. tjnggus caqttlin,J1 ef Ihe isotope whichpadually reduces The precedmg paragraphs have emphasized the son.  ; e amount eresent. The cacretion rate of such materials b ellects, particularly specific ionization. Many * < s been comedered to f ollow much the same pattern as Mry ettocas een be caused by the innuation the radioactive decay of an isotope The tune required guesses it may disrupt smolecules,it may destroy body by the body to eliminate one-half the total quaataty at ass, or the energy sney restely appear m smal form 46 contams is thus ref erred to as -heologscal half; life." h6ast reicaned welhase the absorber. Dependmg on the lo- nl he cxperimental data on excretson seem to ist a power n of the absorbing atom within the molecule. the f unction which is the resultant of a number of esponen.

haustion er.sy or may not disrupt the molecule ll this taals rather than a simple exponential functaon, but the meiscule n m a critecal place within the cell, the cell, concept of biological half life is still used in tiertving hs 1:netion us esa ahdasy to reproducs itself may se permissible levels.

dettoyed Many of these procm are reversible; that Such body deposits may depend on many physiolog.

4. deaage caused by =^1arnia destuptaon or cell dent rue. scal f actora buth m Ihe process of deposition and of eacre.

Een een be reversed by the usual reparative mechamsm cretion. I or many years a high calcium dies was recum.

d the body his a conirred by exgpmental data mended for radium workers, as it was suppo d that a

• ehghow that a,fMal ""' da'* snread out nver i large excess os calcium entering the body would reduce paned al works produces.aamaller ef tert aba the mnc _

the amniini of Ra deposition. AClually, the relallve desfilclivered in a few minugg, However. m the case of radium depoution un a function at the raiso of radium a lasse acute does or conimuod* chrome overexposure, to calcium in the blood stream. Unicas the calcium level there o the possibdsay that non-reversible damage will ,ol the blood is maintamed at a wry high value there will escur still be depmitam of radium. 'Ihe increase in the blood Another type of cell change which as possible is that calcium required to cut the radium deposition by even a the regulative funcimns of a tissue may be destroyed. In factor of three would he impossible to attam.

th e case a cartanoma icancer) may be, produced. As.  !! cuds. Ihe bone structure, common sites of deposition though the mechanism is not fully understood, there is are the e lungand Ivmp!) podra far ^d -", and desect evidence that continued ensult to a tissue may specahs utgann los certam isotopes, such se the thyrood produce this result. lhe high rates el leukemia among for sodine and spleen for iron.

rad:dogists. Imme cancer among Ra dial painters, and A second consideration is that certam creans or tis.

lang 6 enter among miners of the Caschoslovakian, suem are more radiosensitive than others. I he membranes tastman 4siel li h uranium mines all point to radiation immg the bronchi are suppnsedly quite sensitive to rm.

ss the tau ative agent, ihn irreversible damage m d 4 tion and this is ilic primary site of many lung cancers 4's se halum espute wa sprently cumot-ese attribuicd tu mhaled redn>4ctive material. The spleen is sad tie su,suu,lauwe effects led to the illne-also senutive to radiation and relativelv ==o d-mad &amitters. The biologral ettects of radiation have produced more streveruble damur in *=> nr==a from radsuisotopes m the body are comphcated by sev. than m other narts niil7 body. -

tral IAtoss In any determination of radiation effects, lhe organ most likely to be damaged because of the

'hnher in wushms populations or in ammal emperi. comhmed ellects of concentration and radiosensitiverv asnts. the followmg lectors must be considered:(l) the is known as the critical organ for a particular isotope.

• E*te "I iPetshe anotopes m the body, and 128 the in general, any cell m the process of division (mitosis) sielive sensitivity of dallerent tissues to radiation. 86 radiosenutive and for that reason a person is more lhe pencial ellects of esternal radiation have been senutive to radiation during his growing period than as vemusly described but these are certaan modifications an adult. . .

e the tunsederation of radiahon from internal sources. Nadiation injury. The effects of radiation are nan ~.

the hast u that dellerent elementa tend to locahze in cific; s.c., other agents or diseases can cause the same (

lilletent uppens eel the thidv. e y . calcium or strontium damage For ex4:nple, et n imposuble to danar a a bone. ,unn in the red hiood cells, and sodine m the between radiation induced anemia and normallyincident hyroid 1his e, true for any matenal which is metabo. anemia. Oiher posuhle effects such as lung cancer, leu.

und following either mhalation or sagest 6on. Of course, kemia, and bone cancer present similar dt!!iculties.

aany not readil) solubic sutstances will remam in the in any case. where the ellect's of radiation are being mass for long penudo alt r inhalation This means that studied, contlusions can only be (fawn an the '*i af lie 104:1 amount of auth a radioactive malenal is not mcidenEf 4 parikuhiiNg ui"fonar above that run-i istributing its dote unslotmly but rather is 6uncentrat. m3ly e5[trin YtNmp,arshle population. lf tabu.

ng its ellect on a relatewly small traction of the body Iations are made of incidence en a particular group,such l hoost of the heavy metals tend to be depouted in the sa chemical operators caposed to radisuon in a process I

)

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a' .

Attachmsnt 3

• .s.,,

e

,,s Stat R.ec.=tative Stephen bds lettw ta the C NR -- -- -- - -.

August 8, 1979 ,

menorante Joseph n. wendrie, Chairman -

U.S. Nuclear Angulatory Comunission Washington, District of Columbia

Dear Chairmas Mondrie,

4 I as entirely baffled by the apparent refusal of the U.S.

Muc1sar Regulatory Comunission to have extensively reviewed the reports by hundreds of Three Mile Island area residents who, during March 28-31, 1979 primarily, and at tiana subsequent, g

esperienced (a) metallic taste in their mouth (b) metallic or Iodine-like oder in the air

> (c) irritated and watery eyes ,

( (d) moderate or severe respiratory inflammaation (e) gastro-intestinal dysfunction and diarrhea

( f) disruption of the monstral cycle in females j (g) skis rashes (some appearing as radiation burns)

(h) shorp, shaormal pains in joints.

l The U.S. public Bealth Service and pennsylvania State Dept.

of sealth are jointly conducting a survey of TMI area residents .

I to record medical hie m -tes se that the full health consequences

! of TMI' radiation releases in the next 25 years will be documented.

l

'inat is all fine and should be done. But why is there a complete i dismissal by the unc of any Lamediate indications of exposure to levels of radiation higher than what were thiately thought the first dates of the accident? psychosomatically induced a11aents are possible with some, but not with hundreds or even more persons and I suggest this matter has been conveniently 1 aid aside.

The NRC is charged with ascertaining full details about the 1MI accident. You are further charged with knowing the full effects a f even Low level radiation on populations near to nuclear reactors.

l' allure to pursue the aforementioned reports f rom TMI area residents

.i e dismal f ailure of your most important safety responsibilities

• to the tens of millions of people living near reactors, met to non-ti m the people around TMI.

I therefore reeeeenend that all available expertise ye applied to ascertaining the cause of taase physical ailments associated ,

with the TN! accident and a completely accurate public disclosure made of its cause and the level of radiation or contamination that people may have been exposed to. The inability of both Metropo11taa Edison and the NRC to know even to this day (or at least to have disclosed if you actually do knowl the levels of exposure is in itself a major, most serious failing of pro-TMI accident obligationg ,

-q by both parties. And if it is determined that the exact cause of ,

these physical ailments cannot be determined due to the lack of 3  % adequate research on the subject pro-TMI, then the public should

% know the estent to which we indeed are unprepared to deal with

( h, auclear plaat emissions.

• h Yours sinc,erely,, ,

'.. o *,.

t.q . :. ..':', ,,

STEPREN R. REED State Representative 49 o

1 .

Attachment 4 -

Publicat: cns of . a:ner E. Gunckel Y. The Effects of Icniting Radiation on Plants: MorpholoS i cal Effects, The Quarterly Review of Biology, Vol 32, No. 1, March 1957 Modifications of Plant Growth and Develop:nent Induced by Ionizing P.adiations, Encyclopedia of Plant Physiology, Vol XV/2, 1965 Aberrant Growth in Plants Induced by Ionizing Radiation, with Arnold E. Sparrow, Abnormal and Pathological Plant Growth, Brookhaven Sy=posia in Biology No. 6 (1954) .

Ionizing Radiations: Biochemical, Physiological and Morphological Aspects of their Effects on Plants, with A. Mr Sparrow, Encycylopedia.

i of P.lant Physiology, Vol XVI, 1961 il i

e-b 4 l

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4

0 APPE:: DIX A RATIO: ALE FOR DERIVING BASEL1!!E CA'?CER MORT!i1TY DATA FOR THREE AREAS SUR'.":.YED WEST OF n:I .

9 &

I e

9

It has been sugrested thet the expected cancer artality rate used in the Aamodt motion of June 21,19E4 cight not have beca appropristc-1/

The Aa=od s used an expected cancer mortality rate of 215/100,000, the same as the state-wide mortality rate given in the Pennsylvania Vital

- Statistics, 1987. It should be noted that normalization of this rate for age distribution was not necessary since the population age distribution for the study areas, as well as the median age of 38, was essentially identical.

The Aamodes elected to use the state-wide cancer mortality rate to provide the cost conservative comparison with the rate observed in the study included in the Aamodt motion. This cancer mortality rate in rural areas is, as a general rule, significantly lower than in urban areas and, therefore, can be expected to be lower than the state-wide average.

To provide a most realistic esticate of the cancer mortality rate

~

2/

expected in the study area, we have analized cancer mortality data for the townships within which the study areas fell as .c11 as for York County. Table 1 presents population enumerations and esticates.

Table 2 presents deaths and death rates due to =alignant neoplasms.

Data is presented for the fourteen year period, 1973 - 19S3. No data-was available for 19SS, the last year of the study described in the Aa=odt notion.

Fro: Table 2, it can be seen that both cancer number and rate for York 3/

and Tewnship A trend generally upward over the fourteen year period, 1/ Center for Disease Control Review, Letter of September 7,1984, Caldwell, G.

to Mills, Willia: A., Ph.D.

2/ Obtained from the Pennsylvania Departnent of Health 3/ Tcwnship where Areas 1 and 3 of health survey are located.

-l-

1 ,,

• • *~

with censiderable but ressenabic scatter. Township b data shows more severe statter, perhaps even sorc anetslous data points. This latter observation can perhaps be explained by the relatively high growth rate of Township B, 68% between the 1970 and 1980 census, co= pared with 29%

for Township A and 15% for York County.

The data was averaged for thres four year periods, 1972-5, 1976-9 and 1980-3 and standard deviations @r) calculated for death rate averages for York County and the subject townships. The four year average was selected to provide a realistic estimate of the death rate to be expected over the four year study period.

Data for the first two years (1970 and 1571) was not used to allow the use of only 4 year averages. This decision to drop 1970 and 1971 can be justified further on the basis that these data points were, on the average, lower than these used and their absence would result in the calculated expected four year mortality death rate being conservative. .

From Table 3 it can be seen that the township death rate averages are lower than the York County averages, reficcting the expected effect of urban areas (such as the city of Ycrk). The standard deviation fer T:wnship A is a little over twice the standard deviation for York County, reflecting the smaller data base for Tairview Township. The standard deviatien for Township B is three tires that of Ycrk County, also reflecting the s=' aller data base and, perhaps, a screwhat different statistical universe resulting fro: the relativaly high growth rate of Township B from 1970 - 80.

The mean cancer =ertality rates for the two townships are 119.5 and 140.5. The cean can:er cortality rate fer the two townships cenbined ,

is 130,.with a standard deviation cf 7.E. The three signa upper limit i/ Township where Area of health survey is located.

2 La--

t i i

,. en ex; t c ' ccncer r::: *1::- rate it : :'c tw: to nships ec:Fincd is, theref :c , ;53.4/100,03: pepulatien. Tr.is number is higher than the i

l combined cancer mortality rate for the two tov:. ships for any singic year over the fourteen :cors which were analyzed, let alone any four year period. It is, therefore, reasonable to ascribe a 99.7* confidence

~ level (corresponding to a three sigma variation in a normal distribution) _

to an expected maximum cancar mortality rate of 153.4/100,000 for Townships A and B combined, l

i f

9 I

a e e

Q Population Enunnerations And Estirnates For York County, Fairview Township and Newberry Township g 1970-1902 and i903 Provisional York Fairview -

Newberry g County Township Township g 1970* 272.603 9,249 5,978

( /

1971 277,800 NA 9d[B NA 62[7 '

.e 279,3'00 1972 NA G767 , NA 443Y g 1973 282,000 9,627 7,070 1974 284,000 NA ## NA 70 T7 O

1975 285,600 11,032 7,120

$ l976 288,000 ti,372 0,155 1977 289,000 11,355 0,503 0

1970 292,300 11,484 8,851 I

g i979 295,200 NA 1/ ,'/ ! ',' NA i^II 1900* 312,903 11,941 10,047 O

1901 NA NA NA g 1982 319,900 NA NA 1983 317,70Q NA NA O '

• Enuinera ted popula t ion, -a ll other years are estiroated population.

I D E T Cf'!Altl'ito CY /*\ fire.*otA770H g Note: NA roeans not ava i lab le.

Source: PA Departenent of Hea lth

$ State Health Data Center e T@M /

' ~

Resideni Deaihs Due To Halignant th np i isms For York County, Fairview Township and th3 wherry Townt-hip g 1970-1902 and 1903 Pravisiosia t York Fairview .

Newberry g County Township Township Number Rate Number Rate Number Rate g 1970 455 166.9 11 110.9 ,6 100.4 1971 451 162.3 15 NA JQio 3 'UhNA e 1972 494 176.9 13 NA i

/2,2.E'> 14 714. i ilA g 1973 466. 165.2 13 135.0 12 169.5 1974 503 177.1 12 NA / 0 NA (12."7 e 1975 550 192.6 0 72.5 10 252.0 g 1976 503 201.9 14 123.1 10 122.6 1977 561 194.1 11 96.9 11 129.4 e 1970 595 203.6 12 104.5 it i A.3 g 1979 592 200.5 9 NA 76.8 11 ilA I/h 1700 507 107.6 21 175.9 0 79.6 e 1901 509 100.2* 13 100.9* 13 129.4*

g 1902 620 196.3 10 150.7* 14 139.3*

1983 624 1,96.4 20 167.5= 11 109.5*

e =1900 population was used t o c mop u l e the rates.

I bier w r?..p . r ',% :c t'r>.v .>.) vay g thele: Rate per 100,000 population for each specifien area.

NA means not available.

g .'ie . u r c e : PA Department of Health State Health Data Center . .

!= nma 2

~

TABLE 3 Average Cancers / Year Average Mortality Rate x o Range of 3 Arca gverage Population 72-75 76-79 80-83 72-75 76-79 80-83 72-75 76-79 80-83 York 178.0 200.0 192.1 190 5.8 172.5-207.5 County 283,000 291,000 315,000 Towhship 100.7 150.0 119.5 12.6 102.8-178.2 A 10,680 11,420 12,000 11.5 11.5 18.0 107.7 Township 124.4 113.8 140.5 17.7 87.5-193.5 7,090 8,680 10,100 13.0 10.8 11.5 183.4 B

Townships A&B 145.6 112.6 131.9 130.0 7.8 106.6-153.4 Combined 9

4 9

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.* i Attach:nent 5 Exhibit 7 to Gamble Testimony

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Exhibit 7

e. o s y REPORT 13ILITY OF A PREDICTED QTISITE EXPOSURE RATE At about 0740 on March 28, ;973, the licensee attempted to report to h7C Region I the General Emergemer involving known major fuel damage. II During telephone contacts wit 1. Region I personnel, which began at about _

0750, the licensee did not motify Region I of an offsite release cal-culation which predicted significant exposure rates downwind toward Goldsboro.2/ The reportability of that prediction is the object of this investigation.

Except for minor time variamces, matters bearing on the reportability of the offsite exposure rate pned:etion have been described rather consist-ently by TMI-2 accident par de pants and investigators.

A.

Prediction -10CRD27 R/br in Gc:dsboro v

Upon arriving at the plant i'.m :ime to hear a Site Emergency announced at 0655, Howard Crawford, a nue.letr engineer, proceeded to the Unit 2 con-Ae f trol roomy .Urwe-+eefva1 he gttiered materials ;-- --: = = - -' i ,predicti-ng <.%.>;

r'Ma cf-5.1%AY I Ak -

B.La d%,

h rates a task he had performe(during drills for two years. 3y Crawford recalls that his fi: s: calculation, completed soon after 0700, e 4'#*:2 oLAay-i sh4wed an exposure rate of *D 3/hr in Goldsboro. Neither the time3nor i

W resu t of this calculation has been substantiated by records o:.b/the the 0

recollection of others.z, 'E-g ...; Y . -

-- J.nerriy-ptht4en -if--i-t-occurred

%^ a w ,., r - h=~

. m x- y

- h y .- u m a to- "  : : t-i since a similar, documented 4

• w ~ ,.a . n..6

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-.m-.a Mg As 4&%% 4c R/ p': '~ G c-:- c w w - 4

...J t

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(pyi, prediction (10 R/hr at the Low Population Zone boundary) was performed before the licensee reached NRC Region I by telephone at about 0750. N W% 2 a $ W /C'R/K f EW~ mffta ,

=_-JA fr T is prediction g (10R/hr at the LPZ) appears ta have been performed by cO;;h o7/3 % fa * '

ctf-- f Crawford g h mus ,,,. :fter hemassivereleaseofradioactiv[sagtothe M

.. .t 0712 37 .- Both the time and reactor building atmosphere, yn M rhich h.%/DA/6k.fMW,wW3 magnitude of Crawford's dome monitor (HP-R-214) reading (300 R/hr)3 are uncertain. h  :--c; <0t, th; 200 R/hr ru.dius Iu. J the-bas.i- N D

C* r = ' c " ' v i ar. The time shown on the calculation sheet, 0744,, W "'r oy MU.cL,%s ,

unen HP-R-214 was read or when the calculation was per-

, ~.<

formed. -M

't zcfer 7 r. Crawford's prediction of 10 R/hr at the LPZ',.. .

seems to have occurred between 0713 and 0744.

Crawford, recalls discussing a 40 R/hr prediction with Richard Dubiel, Supervisor of Radiation Protection and Chemistry, and with James Seelinger, Unit 1 Superintendent.b!1! Dubiel and Seelinger recall extsn discussions [

only concerning the 10R/hr prediction.8/9/10/11/ M this distinction 40 R/A%MIC Rfk gis unimportant O N w c 1 .

l i &

[ During the 6/6/79 interview,1/ Crawford stated: - -

A.

They both thought it appeared too high and they immediately talked, l you know, possible steam damage to the dome monitor. . .they wanted to get a very good feel to see if they wanted to believe that number....

M On 5/22/79, Dubiel stated:EI 1

s

...I don't think we ever had projections that were meaningful and l

I don't believe at that time we had any projections that indi- j i

. cated anything of a serious nature, even based on the procedures. l This statement appears to have been based on two factors - disbelief of ,

the dome monitor reading and knowledge of low pressure in the reactor ow.7/11/7f e nw building - as indicated in the following exchangeptof -

t Q Do you recall doing an off-site dose calculation at approximately 7:10 on the morning of March 28th?

Dubiel I did not do any off-site dose calculations.

Q Do you recall verifying one?

Dubiel I recall verifying one. I recall looking at several during the morning.

L Q An specifically, do you recall one that was made by 4

Mr. Crawford based on a reading of the dome monitor? -

l l

l Dubiel Yes , sir, I do.

Q Do you remember verifying that one?

l Dubiel Yes, I do.

I

. 3

s -

item is that the dome monitor did not respond accurately.

The projected levels are based on the dome monitor read- l l

ings, plus some very conservative assumptions. Since we l

, are trying to do, in defining the procedure for dose projections, there are a lot of parameters which cannot -

be determined, so that conservative assumptions are made.

And, I feel, first of all, that the dome monitor over-responded significantly.

I feel, secondly, that the building pressure of one or two pounds versus the conservative assumption of 55 pounds would add to it.

fhsh DE5/11/79,GaryMiller,TMIStationManager,Q testified before the U. S.

House of Representatives, Committee on Interior and Insular Affairs:IS!

Weaver: What did you think of that? The high reading on that dome monitor?

l t

Miller: I just did not think about it in terms of fuel damage.

• I knew that it meant there was a potential to release l things offsite. My only concern was to get readings.

Cheney: Did you have any question about the values of those readings?

l 3

Miller: I thought it was too high, but I did not need to be con-vinced that it was high enough to be concerned. It was M%

_;f. ; 40,000 or 50,000. I mean that was beyond what I had ever envisioned ever seeing on the dome monitor,.so.

you can discuss whether there was shielding and moisture and whether it was beta radiation, and all that sort of thing.

But I did not need to be convinced. What I really wanted-was somebody out there with a meter and an iodine kit sampling, and the wind direction. That is real numbers.

That is really what someone is going to get out there.

So that was our concern.

Onsite and Offsite Monitorint

• Mr. Miller's statement reflects a common concern for getting radiation measurements onsite and offsite to supplement the Crawford predictionC4).

Upon declaration of a Site EmerEency at 0655, efforts to organize and dispatch onsite and offsite monitoring teams began. 8/13/ This seems to have occurred rather clumsily; nevertheless, an onsite team (Alpha) was in's tructed at about 0730 to measure the radiation level west of the Unit 2 reactor building. Ab 11 During that survey, th- wind was westward and very light with minute-to-minute variations of about 10 to 30 degrees.

This survey was appropriate, but tardy. At 0746, Alpha Team reported less than I mR/hr at Station GE-8 west of the Unit 2 reactor building.

As discussed later, this measurement became the basis for discounting a.

Cr,e~wferd's prediction (s) of high exposure rates offsite.

6

s At about 0800 and 0830, respectively, Charlie and Bravo Teams were dis-patched by vehicle to Goldsboro. At about 0830, Charlie Team reporte.d less than 1 mR/hr in Goldsboro. Bravo Team reported similarly at about 0940. Giv'e n that there had been no significant release from the reactor building, these surveys seem adequate from the exposure rate measurement standpoint. However, had a major release occurred, these surveys would have been too little, too late.

TMI management appears to have realized the need for a quick measurement in Goldsboro to confirm or deny Crawford's predictions (s). In statements following the accident, Miller and Dubiel maintained that a State Police helicopter had flown a survey team to Goldsboro, soon after the General Emergency was declared.

P 3, , To the U.'S. House of. Representatives, Committee on Interior and Insular A

.?

i Q5 4 n'/HN %I919' s r .~."! j0 Affairs,hMiller stated: y -

).**

, At approximately 0730 or a little before, I had received predictions I

of an offsite dose of 10 R at Goldsboro. This was based on the

~

Reactor Building dome monitor, which was still increasing and from our past experience with this source calculation, we did feel these were really this high, but as a precaution, I dispatched a State

}

Police helicopter with an offsite team along with an offsite team l

t in a car and separately, to the West Shore (Goldsboro).

l 0740 -

York Haven radiation monitor reading (0) - helicopter (approx.) at TMI - dispatched offsite teams in helicopter and one 7

l-

. s .

separately in car to West Shore (from G. P. Miller and R. W. Dubiel recall of the incident).

0800 -

Offsite team in Helicopter at West Shore (Goldsboro) .

(approx.) 'O' reading - we actually were ahead,of the plume -

plus onsite team at our West site boundary 'O' reading.

MbM m 9df/7'?)

2 the NRC Special Inquiry Group , Miller stated:ggj Q. In fact, you or someone called the State Police that morning for a helicopter and you got one very fast, dids't yaa?

Miller There may be---subsequently I know there's some dispari-ties in my time versus the time the thing landed here or the time it's documented. I remember as soon as I had the projection, which was high, for Goldsboro and knowing the west---knowing the wind was blowing to the west and knowing that it was seven or eight in the morning, that l I know that I asked for a helicopter before 'seven thirty.

Ik tha -that wasiin my mind'and knew /that I had the ork jF

/

enmonitoroutove/ r there and I knew had a uy

'/ / l /

on'the West' Shore. at's something that, had pr cticed and tho/ught about it. Even/

/

intheUnft2 hear /ings whe/n

/ /

/ /

wh discussed the wind blowing west, slow as it was.

/

3

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Q Do you know whether the helicopter actually came on the site and picked up somebody to go over the river?

Mille'r To my knowledge it was verified to me that they picked up

. one or two of our people and they were flown over there.

, And readings were back, and as I remember the readings were back before Dubiel had thought the plume had gotten there. In other words, we had gotten over there faster than the radiation would have at the wind speed, which was very slow.

4ls&-

On 4/24/79, Dubielg stated:gj

. At some point around 7:30, Gary Miller asked me for the status of the offsite teams, and I gave him the information that we had two teams ready to go offsite both available for transportation over to the West Shore. Gary directed me to make contact with the State Police and get a State Police helicopter to get one crew over there in a more timely fashion. He was concerned about the traffic--the early morning rush hour traffic trying to go up over the bridge in Harrisburg and then back down and that it might take an hour or more to get over there. He requested that we send one team in a heli-copter and a second team in a car of driving over at a normal pace l

l. to back them up. I do not recall exactly who told me that they l

l would get the State Police helicopter. I believe it was George Kunder, I do not remember exactly, but within minutes I had it confirmed to l

l  ;

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Reportability and Reporting

he situation was intuitively reportable to NRC under 10 CFR 20.403, which requires immediate notification "...of any incident involving , l n l byp rodu.ct. v. . material...which map have caused or threatens to cause... l i

release of radioactive material in concentrations which, if averaged over a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, would exceed 5,000 times the limits specified for such materials in Appendix B, Table II...." W u X ,:.- l 7 3 % M g .

'T7M3rMic. 3 E-p64/M.

Tr h--here twas no reason to believe that the dome monitor (HP-R-214) increase was transient, [he "immediately reportable" concentration of M.Li Xe-133 g 1d Li::. &1.5E-3pCi/ml(i.e.,5000x3E-7pCi/ml). ":i:;

, m.. r "- M.ii.5 C1/no.-end : "/Q ci-2 5E .4 secords per tubic-meter.;-

e Be

"^

0744

.O:

j Crawford g e: d " d.:.ti: E. ... poy " . u s d.. 16O . T4 4ev :--3, s- d-

.d.L.d 2/'5/? u o calculate 3 a concentration of 0.33 C:.mlattheLPZ,22(

.tdi.e. W"M.,. A Wmes <tste "immediately reportable" concentration.q ti g "rin; ;.' e .Y.a 2r-o-M l ny 4.c(!aa th AW .'W K p

"_re &e-mini /C170, nun-eencentration-iemedutely-ceportable--undu yz s.n-be,--foun

'%. 3 c 10 C;"R-MS 26 403-th5"-0 "i ~2orrespond4

/ 15~/ 7 ^--r- M (nW -R 214-reading-W Y f , .

arf- oaly i. '/-hs.

l .

Early in the accident, the licensee logically could have challenged the Procedure 1670.4 calculation on the basis of low reactor building pres-sure. But as the reactor building radioactivity inventory increased, as measured by HP-R-214, the licensee should have become ;;;;r-M.f_f less concerned about the conservatism of the calculation and more con-cerned about the magnitude of the potential hazard.

1

Telephone contact between the Unit 2 control room and NRC Region I was established, after appropriate efforts by the licensee, at about 0750.N Although earlier contacts had been made with the Region I answering ser-vice, this.was the licensee's first good opportunity to report the acci-dent in accordance with 10 CFR 20.403.

J (o,J.7pet/ g g :cieLP2.

However, the 0744 prediction of 10 R/hrgwas not reported, apparently

.because the first_onsite measurement at point GE-8 west of Unit 2 (1 mR/hr at 0746) had been used to calculate a new source term at 0750.

Although this one onsite measurement did not prove that the release was insignificant, the licensee co.uld have concluded justifp, that the

/:

, h44.,<r.'

release was not as bad1=1:tas =g.Aedr- --- 4.

' ' 4- W-g k -0.; _y= -~f the situation

'N WW2 remained however, in that:

,3 (1) the incident still threatened to cause a

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major release and (2) offsite field measurements had not been completed.

Ok \

Y. aJ5

?

N&'E(/ The 11censee4 reported Crawford's 10 R/hr prediction to the Bureau of

&g,c d Radiation Protection but not to NRC. The only identified NRC reference p%5 o

g ,- to a high radiation level outside the plant was the following telephone k' , conversationrecordedifter10:00a.m.on3/28/79 inf the NRC Operations s - -

• l -

f CenteE i

M ^h}r h VOICE: The indications are.that low levels are being released,

,b ve will find out.

• )

eh * ? !t fSA,4 p VOICE: What is your MDC?

, ~: y

/.

m - G.% '

/ VOICE: There is no question that there was -

<(. . a{J.

t?c./,h. ';

n

%* -a i?!

s  ;[y A

% . . . . s.

$'il .

. s . . .

In the meantine, I requested them to try to get their teams somehow to Goldsboro, and they said that the State Police helicopter was there and that they would get one of their teams up in the air and over Goldsboro. We stayed on the phone with them. They found no

. radiation levels onsite or in Goldsboro that would indicate any kind of a leak. So therefore, w ; then notified the Civil Defense to hold tight. This was all before 8:00.

The desire to disprove the 10 R/hr prediction, which could have triggered massive evacuations, is understood. Use of the first onsite, downwind measurementtopartiallyachievesuchdisproofalsoisunderstood.Yg fh use of nonexistent offsite survey results to further disprove the pre-diction is not understood.

j Conclusion l

Nothing discovered in this investigation relieved the licensee of the requirement to report to NRC all pertinent facts concerning the accident.

The 10 R/hr prediction seems not to have been adequately disproved by 0750, when telephone contact was established with Region I. The decision not to report the 10 R/hr prediction was improper. By not reporting to Region I at about 0750 on 3/28/79 that the calculational methoc described j in Radiation Emergency Procedure 1670.4 had predicted a reportable re-lease of radioactive material, the licensee violated the reporting re-quirement of 10 CFR 20.403(a)(2).

l l

,s.

• Attachment 5 Enciosure 1 CHRON0' - 03ICAL BIBLIOGRADHY 1579

1. "Tne Ordeal at Three Mile Island, Special Report," Nuclear News,

~

Apr. 6,1979.

2. "Three Mile Island Nuclear Powerplant Accident," Hearings before the Subcommittee on Nuclear Regulation, U.S. Senate, Serial No.

t 96-H12 Parts 1 and 2, Apr.10, 23, and 30, Oct. 2 and 3,1979.

3. U.S. Nuclear Regulatory Commission, letter from L. Barrett for Distribution, " Preliminary Estimates of Radioactivity Releases

, from Three Mile Island," Apr. 12, 1979.

4. U.S. Department of Energy, " Radiological Response to the Three Mile Island Accident," Apr. 14, 1979.

5. Marshall, E.."A Preliminary Report on Three Mile Island," Science, Vol 204, 280-281, Apr. 20,1979.

~

6. Brookhaven National Laboratory, letter from A. Hull to L. Deal -

'(CES), " Revised Population Exposure Estimate in Vicinity of Three Mile Island Nuclear Power Station, 3/28-4/10/79," May 2,1979.

i 7. U.S. Nuclear Regulatory Commission, letter from A. Brodsky to l J. Liverman (DOE) concerning distorted views in article by E.

Sternglass, May 28, 1979.

8. U.S. Nuclear Regulatory Commission, NUREG h$hhk " Population Dose i and Health Impact of the Accident at the Three Mile Island Nuclear l Station," May 1979.

9. Metropolitan Edison Company, "Second Interim Report on the Three .

Mile Island Nuclear Station Unit-2 (TMI-2) Accident " June 15, 1979.

10. Department of Health, Education, and Welfare, letter from M. Rosen-stein to The File, "Sr-90 and Sr-89 Results for Milk Samples Collected During the Three Mile Island Accident," June 27, 1979.

11. U.S. Nuclear Regulatory Commission, letter from L. Gossick to Senator R. Schweiker describing the public whole body scanning program following the TMI-2 accident, July 9,1979.

12. " Assessment of Offsite Radiation Doses fran the Three Mile Island Unit 2 Accident" Woodard, K. , Pickard, Lowe and Garrick, Inc. , -

TOR-TMI-il6, Rev. O, July 31, 1979.

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=

. 2-

12. Port er-Gert: Consultants, Inc., " Dose Calculations For The Period 4/29/79-5/5/79," PDC-TR-170, Rev.1, Aug. 28,1979.

14. " Follow-up Studies on Biological and Health Effects Resulting from the -

' Three Mile Island Nuclear Power Plant Accident of March 28, 1979,"

Committee on Federal' Research into the Biological Effects of Ionizing Radiation, NIH Publication 79-2065, Aug.1979.

15. U.S. Nuclear Regulatory Commission, NUREG-0600,~ " Investigation Into the March 28,1979 Three Mile Island Accident by Office of Inspection and Enforcement, " Investigative Report No. 50-320/79-10, Aug.1979.

16. U.S. Department of Energy, memo from K. Miller to J. Harley, " Environ-mental Radiation Near TMI: 5/29/79 - 8/21/79," Sept.11,1979.

17. President's Commission on the Accident at Three Mile Island, " Report of the Task Group on Health Physics and Dosimetry," Sept. 28, 1979.

18. U.S. Nuclear Regulatory Commission, memo from R. DeYoung to W. Kreger, -

" Calculated Off-Site Iodine-131 Air Concentrations from Three Mile Island," Oct. 3,1979. -

^

19. President's Commission on the Accident at Three Mile Island, " Report of the President's Commis.sion on the Accident at Three Mile Island,"

Oct. 1979.

20. President's Commission on the Accident at Thret Mile Island, " Report of the Radiation Health Effects Task Group," Oct.1979.

21. U.S. Nuclear Regulatory Commission, NUREG/CR-1093, "Three Mile Island Telephone Survey," C. Flynn, Mountain West Research, Oct.1979.

22. " Report by the Democratic Members of the Select Three Mile fsla'nd Com; mittee on House Resolution #48," House of Representatives, Commonwealth of Pennsylvania, Nov.1979.

1980

23. Sternglass, E., "Inf ant Mortality Changes Following the Three Mile Island Accident," paper presented at the Fifth World Congress of Engi-l neers and Architects,.Jan. 25, 1980.

j

24. U.S. Nuclear Regulatory Commission, NUREG-0637, " Report to the Nuclear Regulatory Commission from the Staff Panel on the Commission's Deter-( mination of an Extraordinary Nuclear Occurrence (ENO)", Jan.1980.

i i

. -3

25. U.S. huclear Regulatory Commission, NUREG/CR-1215, "The Social and Economic Effects of the Accicent at Three Mile Island," C. Flynn, J. Chalmers, Mountain West Research, Inc., with Social Impact Research, Inc. , Jan.1980. -

26. U.S. Nuclear Regulatory Commission, NUREG/CR-1250, "Three Mile Island -

A Report to the Canmissioners and to the Public," M. Rogovin, NRC Special Inquiry Group, Jan.1980.

27. Pennsylvania Commission on Three Mile Island, " Report of the Governor's

, Commission on .Three Mile Island," Feb. 26, 1980.

28. U.S. Environmental Protection Agency, "Long-Tenn Environmental Radiation Surveillance Plan for Three Mile Island", Mar. 17, 1980.

i

29. Letter from S. Book (Univ. of California) to B. Grimes (NRC), evaluating the E. Sternglass paper entitled " Infant Mortality Changes Following the Three Mile Island Accident", Mar. 18, 1980.

30. Houts, P., et al. , " Health-Related Behavioral Impact of the Three Mile Island Nuclear Incident," report ' submitted to the TMI Advisory Panel on Health Research Studies of the Pennsylvania Department of Health, Part I, Apr. 8,1980.

, 31 . Letter from H. Rosenburg (HEW) to R. Goldsmith (NRC), stating number of infant deaths in Pennsylvania for July 1979 (used in Sternglass 1/80 paper) is incorrect and should be revised, Apr. 22, 1980.

32. Franke, B., and D. Teufel " Radiation Exposure Due to Venting TMI-2 Reactor

. Building Atmosphere," Institute of Energy and Environmental Research, Heidelberg, West Germany, June 12, 1980.

33. " Nuclear Accident and Recovery at Three Mile Island," Subcommittee on Nuclear Regulation Committee on Environment and Public Works, U.S.

Senate, Serial No. 96-14, June 1980.

34 Knox, J., et 41., " Utilization of the Atmospheric Release Advisory capability (ARAC) Services during and after the Three Mile Island Accident," Lawrence Livermore Laboratory, Report UCRL-52959, July 1, 1980.

35. " Staff Studies - Nuclear Accident and Recovery at Three Mile Island,"

Subcommittee on Nuclear Regulation for the Committee on Environment and Public Works, U.S. Senate, Serial No. 96-14, July 1980.

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L- -

36. U.S. Nuclear Regulatory Commission, NUREG-0738, (U.S. Envi ronmental

• Protection Agency EPA 600/4-80-049), " Investigations of Reported. Plant and, Animal Health Effects in the Three Mile Island Area", Oct.1980.

37. Takeshi, S., " Assessment of the Release of Radiation and of the Exposure Accompanying Nuclear Power Plant Accidents - The U.S. Three Mile Island Nuclear Power Accident," Kyoto University, Japan, Oct.1980.

l

38. Houts, P., et al., " Health-Related Behavioral Impact of the Three Mile Island Nuclear Incident," report submitted to the TMI Advisory

/ Panel on Health Related Studies of the Pennsylvania Department of Health, Part II Nov. 21, 1980.

39. U.S. Nuclear Regulatory Commission, NUREG/CR-1728, "The Feasibility of Epidemiologic Investigations of the Health Effects of Low-Level Ionizing Radiation," N. Dryers, et al. , Health Systems Division, Nov.1980.

1

40. U.S. Nuclear Regulatory Commission, NUREG-0636, "The Public Whole Body Counting Program Following the Three Mile Island Accident " Dec.1980.

~

41 . Houts, P.,~et al., " Extent and Duration of Psychological Distress of' Persons in the Vicinity of Three Mile Island," in Proceedings of the Pennsylvania Academy of Science, Vol 54, No 1,1980.

i

42. Tokuhata, G. , "Three Mile Island Health Effects Research Program "

in Proceedings of the Pennsylvania Academy of Science, Vol 54, No 1. ,19-21,1980.

1981 l

43. Brotto, C., "TMI Cover-Up Charged," The Patriot, March 26, 1981.. .

44 Tokuhata, G., " Pregnancy Outcome Around Three Three Mile Island,"

presented at the conference: Linking Public Health Social Worker and Public Social Services for Comprehensive Care for Mothers and Children.

l l

University of Pittsburg, PA, Mar. 29 - Apr. 2,1981.

i l

45. U.S. Nuclear Regulatory Commission, NUREG-0754, " Impact of the 1979 Accident at Three Mile Island Nuclear Station on Recreational Fishing in the Susquehanna River," Mar.1981.

46. " Effects of TMI Accident on Infants Are Debated.by 2." The Patriot, l Apr. 23,1981.

I i

1

.. 1 47 Pasciak, W. , et al. , "A Method for Calculating Doses to the Population from Xe-133 Releases During the Tnree Mile Island l Accident," Vol 40, 457-465, Apr.1981. _ l

48. U.S. Nuclear Regulatory Commission, NUREG/CR-2063, " Effects of the Accident at Three Mile Island on Residential Property' Values 1 and Sales," Gamble, H. , and R. Downing, Pennsylvania State University, Apr.1981.

49. Houts, P., et al., " Health-Related Behavioral Impact of the Three Mile Isl4nd Nuclear Incident," report submitted to the TMI

! Advisory Panel on Health Research Studies of The Pennsylvania Department of Health, Part III, May 12, 1981.

50. Bowden, M. , "TMI a killer? A harsh debate, a decades-itng wait,"

Philadelphia Inquirer, June 8, 1981.

51. Tokuhata, G., and E. Digon, " Fetal and Infant Mortality and, Congenital Hypothyroidism Around TMI," presented at the International Symposium on Health Impacts of Different Sources of Energy, Nashville, TN, June 22-26, 1981.

52. Shuping, R., "Use of Photographic Film to Estimate Exposure Near TMI," Health Physics, Vol 41,195-199, July 1981.

53. U.S.- Department of Energy, GEND-008, "The Citizen Radiation Monitoring Program for the TMI Area," DOE Contract No. DE-AC07-76I001570, July 1981.

54. Maclead, G., "Some Public Lessons From Three Mile Island: A Case Study in Chaos," Ambio, Vol 10, No 1,18-23,1981. ,. ,

55.. Tokuhata, G., " Impact of TMI Nuclear Accident Upon Pregnancy Outcome, Congenital Hypothyroidism and Infant Mortality," chapter prepared for Energy. Environment and the Economy published by the Pennsylvania Academy of Science, 1981.

1982

56. Shuping, R., "Use.of Photographic Film to Estimate Exposure Near the Three Mile Island; Nuclear Power Station," Bureau of Raciol,ogical Health, U.S. Department of Health and Human Services, FDA 81-81'2, Feb. 1982. -

57. Goldnacer, M., and J. Lehman, " Crisis Evacuation During the Three Mile Island huclear Accident: The TMI Population Registry," l presented at the 1982 Annual meeting of the American Public Health  !

Association, Montreal, Quebec Nov. 16, 1982.

58. Kaufman, M., "TMI-Suit Attorney Announces Health Study,"

Pniladelphia Inquirer. Dec. 9,1982.

59. Rao, G. , et al . , "The TMI Population: A Closer Look," in -

Proceedings of the Pennsylvania Academy of Science, Vol 56, No 1

, 1982.

1983

60. Goldhaber, M., et al., " Moving After the Crisis-A Prospective Study of Three. Mile Island Area Population Mobility," Environment and Behavior, Vol 15, No 1,93-120 Jan.1983.

1

61. U.S. Nuclear Regulatory Comnission, letter from W. Dircks to Commissioner Ahearn, " Draft Letter to Ms. Brenda A. Witmer,"

Juhe 14, 1983.

62. Goldhaber, M., et al. .. " Spontaneous Abortions After the Three Mile Island Nuclear Accident: A Life Table Analysis," Am Journ of Public Health, Vol 73, No 7, 752-759, July 1983.

63. " Petition for Authority to Make Expenditures From the TMI Public Health Fund Relating to Improved Radiation Monitoring of the THI Facility Under Paragraphs 10(a),10(c), and 10(d) of the Settlement Agreement," U.S. District Court for the Middle District of Pennsylvania, Civil Action No. 79-0432, Nov.10,1983. , ,

64. Goldhaber, M. , et al. , "The Three Mile Island Population Registry,"

Public Health Reports, Vol 98, No 6, 603-609, Nov.-Dec. 1983.

l 65. Bratz, J. , "The Three Mile Island Mother-Child Registry," Health Reporter, Vol 4, No 12,1,4, Dec.1953.

66 Gur, D., et al., " Radiation Dose Assign ent to inoividuals Residing Near the Three Mile Island Nuclear Station," in Proceedings of the Pennsylvania Academy of Science, Vol 57, No 1, 1983.. ,

i

l

-7 1984

67. Tokuhata, G., "Three Mile Island Nuclear Accident and Its Effect on the Surrounding Population," Pennsylv ania Department of Health, Division of Epidemiology Research, Jan.1984

68. Houts, P., et al., " Utilization of Medical Care Following the i Three Mile Island Crisis," Am Journ of Public Health, Vol 74, No 2,140-142, Feb.1984

69. Fabrikant, J., " Nuclear Energy, Public Health and Public Pol' icy,"

Health Physics, Vol 46, 739-744, Apr.1984 i

i

70. Tokuhata, G., " Health Studies in the Three Mile Island Area,"

presented at the special session on Health Effects of Radiation at the annual meeting of the American Nuclear Society, Miami Beach, FL, June 7-12, 1984

71. Tokuhata, G., "Epidemiologic Surv eillance in Pennsylv ania: AICase of Nuclear Power Plants," Pennsylvania Department of Health, June 1984 -

72. Cherskoi,M., " Blowing the Whistle on Radiation Danger," American Medical News ,13-14, July 13,1984

73. Beyea, J., "A Retiew of Dose Assessments at Three, Mile Island and Recommendations for Future Research," prepared for the TMI Public Health Fund, Aug. 15, 1984 74 Tokuhata, G., "Three Mile Island (TMI) Nuclear Accident and Pregnancy Outcome," to be presented at the XII International Biometric Conference, Sept. 2-7, 1984 , ,

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Enciosure 2 IT*TU5 0 F. A: :0.03::A. !":::T STJ0:E5*

- ~ ;.J' e THE ACC.' Olig Ai TH:.EE MILE IS'_AND 1.s a result c d tne accisent at inree Mile islanc, Unit 2, the ra:1ol ogi cal en. ;rens of the site nave oeen the su:,iect of intense, and com;renensiv e I 1

radiation monitorin; and radiological impict studies. These ine es-ig ations included assessment of the causes of the. accident and of the raciation ex- (

osures and pc ential impacts, during and subsecuent to the accident: to the workforce, the general population within 50 miles of the site, and the terrestrial and aquatic environment relative to iffects on domestic animals and wildlife. Many well known and respected agencies and organizations par- 1 l

ticipated in this effort to assess any impact resulting from the accident. .

Among those conducting the most comprehensive radiological assessments were:

De:artment of Energy (DOE), Department of' Health, Ecucation anc *.'elfare (HEW),

Environnental Protection Agency (EPA), Commonwealth of Pennsylv ania, Metro-politan Edison Company, and the Nuclear Regulatory Commission (NRC).

The radiological monitoring programs which these groups initiated during the first few days after the accident included the placement of environmental thermeluminescent dosimeters (TLDs) within a 20-mile radius of the site, aer- ,

ial . and ground radiation surveys, monitoring of licuid effluents f rom the site, i sampling and analys.is of local milk, food, soil, v egetation, and grass samples ,

In addition to these monitoring and ar.alysis of s*urf ace and drinking water.

programs, the utility had TLDs ano air particulate monitors in place at the time .

tha accident re;an. In order to assess if there was any potential airborne

o-ta-inaiion, a whole body counting system aas set up in ".iddletown twelv e

-2 cays afte- tne accident. Wnole oody counts of 753 men, women, and chilcren living within 3 miles of TMI were successfully performed during tne following 21/2 months with no significant findings 6f radioactke contaminates in any of the individuals.

Radioactiv e Releases The principle radioactive materials released to the environment appear to be the noble gas isotopes of xenon and krypton, as well as trace amounts of radio-iodines, primarily 131 1 The primary xenon isotope released was 133 Xe. All of the krypton isotopes released during the accident hete relatively short half-lives and no measureable quantities of these isotopes were detected immediately.

1 following the accident. Monitored v enting of the TMI-2 reactor containment building a year after the accident (June 28-July 11,1980) resulted in a fur-ther release of approximately 44,000 curies (Ci) o'f '8 Kr. Estimates of the to-tal amount of noble gases released during the accident range from 2.4x10 6, g 13x100 Ci, with the lower estimate being the most accepted one. Between 14 and 15 Ci of 11 1 are belie /ed to here escaped from the plant. Plaht HEPA and char-l coal filters presented particulates and most of the airborne radiciodines from l

escaping. ,

At least 17 isotopes in measureable quantities were released to the Susquehanna

! Riv er from tne TMI site in the 45 days following the accident. (The City of Lan-caster a;reenent of 2/27/80 pronibited the discharging of any further accident' generated waste water into the Susquehanna Riv er. This ag reement was not v iolat er.

": t of tr.e is: ::es released were release: in icw concentrations anc at infre:.c-

. . _ _ - _ . ___ . _ . . . _ . _ - ~. . . - - ._. _ _ _.___ _ __ _ - . . _ _ _ .

3 in e N ai s". Results of calculations to cetermine the maximum doses that an in-cividual would receive as a result of ingestion of water and fish from the Sus-quena'nna River indicate that the health and safety of the public was not endan-gered, nor was there significant emironmental impact.

Emironmental Monitoring and Samolino Results Assessment of the TLD and other monitoring data indicate that the major offsite releases of radioactive materials occurred on the first day of the accident. The nighest direct mea'surements were obtained on site (3000 mR/h (p+r) and 400 mR/h (y) indicated in the plume over the plant on March 29] and at nearby Kohr Island.

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"The release quickly disspated and exposure levels on the ground on-site were or-ders of magnitude less" (NtJREG/CR-1250, p. 389). Measurements indicated that the plume trav eled to the north-northwest. ,

In general, following the accident, lev els of 1 31 1 detected in air samples were 3

on the order of a few picoeuries per cubic meter (pCi/m ) or less (the maximum l

permissible concentration (MPC) in air in an unrestricted area is 100 pCi/m3),

1 31 3 This mea-ine highest observ ed I concentration offsite was 110-120 pCi/m .

surement was made, on April 16, 1979, four days after changing of tne filters in TMI's process ventilation was initiated.

Foilowing the accident, thousands of emironmental samples (of air, water, milk',

ve;e ation, soil, anc foodstuf fs) were collected by the various g roups monitoring the area. Of the radionuclides detected (I39Cs; 895r and 90Sr,133xe, and 131:)

in s: e of tnese samples, "only v ery low le< els of radiciodines and racioxenons .

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c-car. ce at--itutec te releases f rom the accicent "(NUREG/CR-1250, p. 329). Tne trace cua'n-ities of raciocesium and radiestrontium cetected in a few samples are attributed to resiouai global fallout from previously condu:teo nuclear wea-pens tests. Of the hundreds of samples of milk taken, small concentrations of 131 1 were detected in only a few s ampl es . The highest concentration found was 41 pCi/l in a sample of goat's milk. This lev el is well below the EPA pro-teckiv e action le/ e1 for milk of 12,000 pCi/1. In an article in Scidnce, E. -

Marshall states that " China's most recent nuclear bomb test raised the iodine lev el in milk near Harrisburg to around 300 picocuries per liter". Of the o<er 800 samples (of soil, grass, water, and air) collected by DOE.131 1 was found in only a few air and grass samples and ,this was a't lev els only sligntly~ abov e the

, =inimum detectable activities (MDAs). In an interacency EPA meno (9/11/79) to J.

Harley, K. Miller states that in situ gamma-ray spectra measurerents made at 7 DOE monitoring sites showed "no indication of unusual contamina . ion at any of

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the sites". "The low levels of radiciodines and traces of radioxenons collected l

! in eruironmental samples taken from the area around the TMI Station confirm that releases of radioactive material from the accident were not significant, All of the offsite analytical results were significantly below reculatory limits" (NUREG/

CR-1250, p. 390).

! =

i In the conths following the TMI accident, there were several questions raised con-

~

cerning p:tential effects en animal and plant life in the TM: area. The Pennsyl-L v ar.1a Department of Ag ric*.,1.ure (FDA) corducted a numter of sure eys to determi,ne l

1 ansther there were any unusual agricultural proble s which could be related to l'.1.

E e cf the t,.ues cf anical health ;ro:lems irre estigated include: re;reductica .e_

l  :'.i s, ::re E : ;s:le : :rie , 2.: ucei:1 2ine deaths. Re:.:r.e: c'fe:ts : 1 .

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5-a-ion were also stuciec. Tne results of tne above stuoy found that "none of the reported plan. and animal health effec s...can be directly attributed to the operation or the accident at the TM1 Nuclear Power Station" (NUREG-0738, p.29). '

Estimates of Doses -

Radiological monitoring of the environment by EPA, HEW, DOE, Metropolitan Edison, ano the Commonwealth of Pennsyly ania " confirmed that radiation lev els off site were quite low and remained so during the course of and subsequent to the accident" (NUREG/CR-1250,p.,398). TLD data indicated that the maximum dose would_be re-ceived by an individual located on the east bank of the Susquehanna River. __

Esti-mates by the Ad Hoc Interagency Dose Assessment Group, the President's Task Group on Health Physics and Desimetry, the Department of Energy, and others show that the maximum offsite individual dose was less than 100 mrem. The highest actual individual offsite dose indentified was receiv ed by an individual who was on near-by Hill island for short periods of time during the accident. The Ad Hoc Group and the President's Commission calculated the most probable dose to this in-dividual to be 37 and 50 mrem respectively.

Se<eral incependent studies were perfomed using dif ferent methodologies to es-timate tne colledtive cose to the population (approximately 2,164,000 people) living witnin a 50-mile radius of TMI. The results of these studies were simi-lar, witn the maximum population dose estimates indicating that "the population cose could not nav e exceeced 5000 person-rems" (NUREG-1250, p. 399). The esti '

mated annual collectiv e dose to this population from natural backg round radia-ti:r is a: cut 2c0,000 person-rems.

. . E. .

Tnt a.erage cose to an inoivioual in this population was estimated to be no more .

than 1.5 mrem. The HEW Puolic Health Service attempted to deter.T.ine offsite, ex-posure from photographic film present in stores in the TMI area during the first three days after the accident. They concluded that ev en if the fogging noted on the purchased films was attributed to radiation exposure, the total dose would be les's than 5 mrad.

Conclusion Tne President's Task Group on Health Physics and Dosimetry concludes that in spite of serious damage to the plant, most of the radiation was contained and "Ihe actual release will have a negligible effect on the physical health of in-div i oual s" . The average individual dose of approximately I to 1.5 mrem is equiv a-lent to about one percent of the yearly exposure dye to natural background radia-tion in the area. The President's Task Group states that "the major health effect of the accident was found to be mental stress".

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APPENDIX A CRITIQUE OF CENTER FOR DISEASE CONTROL (CDC)

RESPONSE TO AANODT STUDY e

9 $

, . - - - -, - - , , - .- . _ . ~ - - - ,-.-m, - .

9

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• CRITIQUE OF CENTER FOR DISEASE CONTROL (CDC) RESPONSE TO AAMODT STUDY Norman O. Aamodt The CDC letter contained 23 criticisms of the Aamodt data

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and related analysis.

Each criticis,m is considered in the order given.

1. CDC asserts that the areas listed are "out of the highest exposed areas", citing as support the "May 10, 1979 prelininary dose assessment report."

This position is flawed on two counts: A principle purpose of the Aamodt motion was to challenge this and similar dose assessments, noting that radiation release records from TNa-2 are missing for the early hours of the accident, that wind patterns were such that these releases would have passed over the study area and that the observed effects tended to support their position. CDC demonstrates an unobjective attitude by attempting to discredit the data by

~

inferring that it simply was not possible.

2. The individual of Affidavit 2 consulted a physician and was told that his symptoms (the symptoms listed both in the body of the motion and in the attached affidavits) were typical of those expected from severe radiation exposure but could not have been since no significant amount of radiation excaped during the accident! Further, any reasonably well-read member of this society can recognize the observed symptoms as similar to -

those resulting from severe radiation exposure. It is, therefore, suggestive of extreme bias that Dr. Caldwell, a medical doctor, did not.

3. Yes. Individuals from all of these agencies as well as Dr. George Tokuhata of the Pennsylvania Department of Health and Governor Richard Thornburg (Pennsylvania) were asked to consider them to no avail.

4. Any bias any interviewers may have had was overcome by the use of a survey questionaire and specific instructions to each interviewer regarding 1/ See Attachment 1 - The CDC letter, Caldwell to Mille, September 7, 1984

2 its use. Then, the person interviewed was asked to look over the form to be certain that it fairly reflected the information provided end to sign it.

5. This information, gathered outside the study area, was clearly identified and not included in the data analysis, i. e. cancer mortality rate.

6. The lump appeared after the accident. The afflicted person had

~

not sought medical attention by the time of the survey.

7. This finding results from a calculation of the ratio of the number of reported (and confirmed) cancer deaths in the study population to the number of cancer deaths predicted by the Pennsylvania Vital Statistics. Since 4

the cancer mortality rate in York County and rural areas, in general, is lower than the state average, a most conservative cancer mortality rate was derived.

The data is clearly presented in the Aamodt motion. The fact that cancers may have been present before TMI is irrelevant. Three cancer deaths

. were expected. To excise any of these because of earlier diagnosis would have been in error.

8. This is in progress. The appropriateness of medical review in no way denegrates the validity of first-hand accounts of personal cxperiences or descriptions of persoan physicians' diagnoses.

9. Had CDC read the motion carefully, it would have been clear to them

! that this was precisely the Aamodts' position. The Aamodts used first-hand l accounts to infer hypotheses which, in their motion, they requested the

! Commission to test.

10. a. CDC does not specify the area in which they allege the data is i

l incomplete. It is true that some residents could not be contacted. It is l

also true that some persons may, for various reasons, have been unwilling to l

l acknowledge that they had cancer. Both of these aspects of " incompleteness" l

, would only cause the calculated cancer mortality rate to be higher, adding l

l an element of conservatism to the study. Death certificates have been

obtained fer 19 and in all cases the listed immediate cause of death was cancer (after lost of breath). The 20th death certificate is expected one

-shortly. Two other reported cancer deaths were dropped /because death occurred before 1979 and the other because cancer was not listed.

Two cancer deaths, not having occurred at the time of the survey, were .

verified sad included. The period presently considered in the survey are the years 1980 - 1984.

b. As set out in Figure 1, the age distribution is such that the median age range is 35 - 39, identical to the Pennsylvania Vital Statistics. Sex and race adjustment are not ordinarily made in the Pennsylvania Vital Statistics Report on cancer mortality rate. In any event, such adjustments could not be expected to raise the expected rate by anything near the factor of 4 or more ne'eded to make the conclusions of the study invalid,

c. Date of diagnosis may be important in assigning cause. It bears no relevance to computing cancer mortality rate. Further,CDC presents no basis for its assumption that a cancer resulting from exposure from the THI-2 accident must necessarily take at least one year to develop. Neither CDC nor anyone else knows precisely what the active agents may have been. To exclude cancers diagnosed prior to the accident from a calculation of cancer mortality rate . .

would be at best capricious.

l d. CDC presents no evidence that cancers cannot occur without a "long" l latency period. Short latency periods are known to occur. Note the literature on organ transplants and the effect of depressed immune systems. Could the l

role of a causative agent emitted from TMI have been to suppress the immune system? In any event, eliminating 1979 data, when only one cancer death occurred, only increases the cancer mortality rate.

e. Verification does now exist, as stated (10.a.) abover l

l l

f. Age distribution coincides with Pennsylvania Vital Statistics. See 10.b. above.

I

g. This is true. The baseline data used (Pennsylvania Vital Statistics) yields a very conservative result. Rural areas, such as those surveyed, can be expected to have a lower cancer mortality rate than the state average. We

~

have obtained data from the Pennsylvania Department of Health providing population and cancer death statistics back to 1970 for the townships in 2/

which the survey was made. This data was analyzed and yielded an expected cancer mortality rate of 153.4/100,000 in contrast to the statewide rate of 215.6/100,000. Using the figure of 153.4 and adjusting the' survey data to only include the years 1980 - 1984, the actual present cancer mortality rate in the study is seen to be 7 times the expected rate.

11. The incidences of the tumors and cancers were mostly post-accident.

Nineteen of the 26 tumors / cancers occurred post-accident. These data Jare believed to be reliable. They are based on interviews with actual afflicted persons and/or close relative. One tumor / cancer is known to be pre-accident.

The others need to be checked. Further, number of tumors found can be expected to be conservative because of some victims' reluctance to disclose

- this kind of information. In several instances, the victim required several follow-up contacts before he/she would admit to and discuss the existence of

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a tumor. The number of tumors / cancers in living cannot be compared for expectancy to the total population of the survey areas (433) but rather to that for the families contacted (298) because of the reluctance observed.

Whereas cancer deaths were public information, it appeared, and the total population was used to calculate the cancer mortality rate, cancer / tumor diagnosis is a private affair in the areas surveyed around TMI. The Pennsylvania tumor registry could be helpful if it were available.

2/ Appendix A to Aamodt Study, Revision 1

12. a. There is no definitive data in existence to describe the full spectrum and concentrations of the potential health antagonists that were released from TMI-2. The processes involved in the detonation of a bomb and the normal and abnormal operation of TMI-2 yield vastly different sets of antagonists, so that " Hiroshima" data (which itself is not yet fully understood and did produce a spectrum of short latency period cancers) cannot be used as a model for analysis. The singe isotope exposure data gleaned from medical experience is also of no significant value in determining the effects of radionuclides appearing in combination with a host of potential co-reactants.

CDC's assertion that the latency period was inadequate to allow the development of observed cancers is unfounded.

b. As discussed in 12.a., this position is fatally flawed absent an accurate analysis of TMI-2 emissions,

c. The assertion is faulted on two counts. First " radiation alone" cannot be demonstrated to the the causative agent. Secondly, there is no basis to assert that "only blasts" can cause a collapsed organ. No evidence was presented to infer that the organs collapsed as a result of physical impact.

Rather we find the presence of what appears to be a grossly excessive number i

of collapsed organs provocative. We would suggestthat CDC (and others) take , ,

notice of the fact that organs collapse when muscle tissue is impaired.

Radiocesium (and perhaps other materials in the TMI-2 reactor vessel inventory) have an affinity for muscle tissue. To suggest a relationship of organ collapse to the TMI-2 acsident is not, at this early stage of investigation, unreasonable.

l Further, the collapsed organ data was included to provide as complete a picture as

! as possible of the current state of health of residents in the study area, l

13. Interpretation of the data was not attempted. An atteept to gain access to medical records was beyond the scope of the study but clearly within the scope of the investigation requested of the NRC Commissioners. Diagnoses have now been rediscussed with many of the afflicted individuals, and this data is reflected in Revision 1 to the Aamodt study. None of the reported tumors were mosquito bites. Medical records have been requested.

14. CDC's perception demonstrates negative bias and is a direct conflict with medical opinion as related by afflicted individuals.

15. CDC does not consider the effect of diminished muscle function .

a (See 12.c.) To ignore this data could be/very serious mistake. Cesarian sections were the most frequently occurring abnormality. This finding was to be expected in light of animal data which suggest a fourfold increase in Cesarian' sections on local farms.

16. This assertion that " lack of an adequate, contemporary control group.,

.. weakens even the possibility of arriving at a reasonable conclusion" (emphasis added) demonstrates appalling bias. It is also false on three counts:

a

1. The Pennsylvania Vital Statistics provide / meaningful, conservative control group.

2. CDC is aware of the existence of appropriate township statistics which can accurately describe baseline conditions. In fact, as discussed above, ,

the Aamodts have obtained this data. Calculations using this data further demonstrated the conservative nature of the Aamodt conclusions.

3. CDC possesses the expertise to know that any fourfold (let alone 7 fold) departure of cancer mortality rate from state averages cannot be expected to go away by baseline modification and that such a departure is symptomatic of a significant insult to the study population.

l'.* 17. Th2 Aamodt cotion stated the number of tumors in living persons "suggest" a continuing excess cancer mortality. It did not present this suggestion as a conclusion. Further inquiry in this area would result from approval of the motion by the NRC Coc=issioners.

18. The assertions that the affidavits are " testimony and opinion" but"not scientific -data"is an absurdity which could support a conclusion that the CDC response is fatally flawed by bias. CDC knows full well that the raw statistics derived from surveys provide the base data for innumerable

" scientific" studies in numerous disciplines.

19. Unless CDC can present definitive data to support their view (see answers to 10. c. and d.) this assertion can only be viewed as demonstrating bias.

20. Yes. Dr. Gunckel described the thoroughness of his investigation in his affidavit 5.

21. CDC overlooked the Reed letter (Attachment 2 to motion) in characterizing the number of residents reporting errythema and other symptoms as "sevenal". Reed stated that hundreds of people called him and described similar symptoms. Thousands of people have called the Commonwealth of Pennsylvania concerning their experiences. We are attempting to obtain these records. As Representative Reed asserted, hundreds of people did not imagine similar experiences. CDC also overlooked Af fidavit 2, where in the individual stated that he described his symptoms to a doctor the day following his experience and the doctor noted that the sympto:s were similar to those expected from radiation exposure. However radiation exposure was ruled out on the basis of the official position that "no radiation got out". The doctor's bias is i understandable. CDC's is not. CDC exhibits further bias by assuming i

other causes for the observed symptoms. CDC should also carefully c.ansider the fact that nofone individual has yet been found that had experiences nrior to the TMI-2 accident.

S-

+

• 22. CDC again exhibits incomprehensible bias, this ti=c by rejecting out of hand the observations of trained professional people. This anecdotal information is not presented as " data". It is provided to assist the reader in grasping the gravity of the problem. In its place, this paragraph is provacative.

- 23. CDC again exhibits bias in an assertion that it is "unlikely" that an increase in cancer deaths could be expected given the noted health effects. No basis other than bias is given or implied other than to discard out of hand the validity of the observations noted in the study.

A great number of the questions raised b CDC could have been resolved by means of a phone call to the Aamodts. The fact that CDC made no attempt to follow-up with the Aamodts is a clear demonstration of the cursury nature of their review. The fact that CDC discards the study conclusions out of hand without a single example of solid basis demonstrates severe bias. The fact that CDC concludes with a suggestion for a follow-up study is evidence that CDC does not take its own objections to the Aamodt study seriously. The fact that CDC suggests that this followup study be . based on a census of their own taking which as been described as useless gives telling evidence that CDC could well be part of a conspiracy to coverup health effects from

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the accident at TMI-2.

. ?.- .

t% Public Health Service DEPARTMENT OF HEAL.TH & HUMAN SERVICES Centers kr Olsem Conuot Atfanta OA 30333 September,7, 1984 s

William A. Mills, Ph.D. ,

Chief Realth Effects Branch ,

Division of Radiation Programa -

1 and Earth Sciences Office of Nuclear Regulatory Research

,Mc wk,h I U

Nuclear Regulatory Cosnission Washington, D.C. 20555 Dear Bills I received the AAHODT document from you and anothat about tSe esse Much time to my from Dr. George Tokuhaca of the Pennsylvania Department of Health.

surprise they are different. The copy you sent is missing pages and 2, Attachment4, 6, 9 11, Figure 1. Affidavits 2, 4, 7, 9 and parts of Affidavin '. .

2. Dr. Charlea Stutsman, Dr. Matthew Zack and I revisOd the Tokuhats version and the following souments are a compilation of them.

In the -

We believe that there are a number of deficiencies evident Following are our epidemiologic aspects of the data presented in this report.

t combined comments.

/R The areas listed ave outside the highest exposed

. ,l '.

1. Pages 1, 4. Figure 1. areas and sway from the predominant areas, (NNWi EF i

the May 10, 1979; preliminary dose assessiiienti eport.

2.

Page 1, p'aragraph 3.Was Whoa diagnosed the radiation related healthWhat vers th physician consulted?

effectet

3. Fase 1, paragraph 3. Was anyone from the state. EPA, DOE, MRC, or DsDA(. -

requested to investigate the plant problemsf ,

4. Fage 3. paragraph 4; page 4 paragraph's 2 and 4. ' ~ -

Appear to represent * ['

interviewer, bias.~ . '

5. Page 4, paragraph 3.

Appears to represent both selection and volunteer '

bias. .

'~

Was it possible the lutsp was pra sent before the TM1

6. Page 4, paragraph 4.

accident? Was date of diagnosis sou5ht? r, Deaths may be(C

7. Page 5, 3.2.a. This is an assertion. What'Is the dataf

! 'i tw " - p,k :

incrossed but cancers present before_THI. &.a..! i

s. Page 5, 3.23 rend ~ e7 A11 disguoses and datsa of dingT ones need to be confirmed by med! 21 records review. * '

. - . _ , - _ . . - - _ . , . - . . _ . . . . . . ..__.,_..m.,.m.,_,w..y. .r_m.m- . _ , , , _ , , _ , _ _ _ , . -..,_,,y.m.,,,_,..,--,,,,

Fcge 3 - Willism A. Mills, Ph.D.

17. Without annual comparison data, the conclusion of ./ a:"c'ontii.uing" excess '

cancer mortality rata la unfounded. (, .r . '. ew u. W u. . i'

18. Page 7, 3.24. . Affidavits are testimony and opinion, not seientific data, b

19. Page 8, 5.0, Bentence 1 and 2. Data inadequate to support these {'

- statements.

Fase 8, 5.0, sentence 3. Wars plants inspected / studied' for any cause [

<~

20.

except radiation. (e.g. insects, chemicals, plant disease, and of life _

po i k. W span, etc.)-

22. Page 8, 5.0. The dose estimates presented in this paper. of 100+ t'em appear to be based solely on anecdotal reports by'seversi casidents of reddening of ths. skin (erythema). "Allhough we agie'e%t trythema can resnit from high dose radiation exposure, not all erythe na results fron ioniains radiation but from other things such se sunburn, elle.rgy, drugs, l r;muu-

etc.

, p r- hat

22. Page 9, paragraph 1. Discussion confuses cancer deaths and cancer incidence. That " life is terminated" more rapidly is a eenclusion (.

c

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\ % kt,s p g J otally unsupported by the data presented.

23. Page 9 paragEsph 2[ No, data _is presented to show t)dit tt ere is sa b' slarnios increase in hfalth problems, only a possible, but likely unrelated, increase in cancer deaths. N g This paper does not present convincing evidence of cancer incit'enee, eaticar soortality, or adverse pregnancy outcome in TM1 area residents following the cccident. The proper way to address this concern is through t1.e Pennsylvania The Centers for bisease contral, Department of Health's THI followup program.

National Insti':utes of Health, and Pennsylvania Health Departennt comb'ined resources to develop a census of the.0-5 mile residents shortly after the cceident. Although that effort was crithized at the time ar. useless it might

' still be useful for Nic to fund additional scientifically valid followup studies in that population. * -

I hope this bryf , review.is helpful.

Sincerely yours, Clyn G. C idwell, M.D.

Assistant Director for Epidemiology chronic Diseases Division conter for Environmental Esalth ,

W _w .c.e w--y,-.= ,y,,w.-e,-,, -- - , . -. ,,-,,-,--,-+--m-+,,--e-.-.-~.~ -----*-----,-e-+

o N

s **%i APPENDIX B THE THREE MILE ISLAND ACCIDENT USE OF PHOTOGRAPHIC FILM FOR DOSE ASSESSMENT Norman O. Aamodt, M.E.

w

• e

! s i

a I

e

- THE THREE MILE ISLAND ACCIDENT AND USE OF PHOTOGRAPHIC FILM FOR DOSE ASSESSMINT*

Norman O. Aamodt, M.E.

Analysis of photographic film could have provided a reasonable exttmate of population exposure resulting from the TMI-2 accident.

1/

Only one such study was conducted and it was seriously deficient.

To develop a meaningful dose assessment from the analysis of photographic film samples at least four experimental design criteria must be met:

1. Sample size with regard to angular distribution must be sufficiently large to assure the absence of " windows" through whidh a plume could pass undetected.

2. Sample size with regard to linear distance and elevation must be sufficiently large to assure that the effects of terrain on meteorlogically and topographically induced deposition characteristics are considered.

3. Radiation dose response must be known for film sa=ples.

4. The effect of storage parameters on net density of the developed film must be known.

The HHS study gathered samples of photographic film from 5 locations (2 NW of TMI, 1 NE, 1 E and 1 S of TMI) and from 8 locations in R,ockville ,

and Frederick, Maryland. The five sample locations in Pennsylvania are clearly inadequate to meet requirements 1 and 2 (above).

1/ HHS Publication: FDA 81-8142, Use of Photographic Film to Estimate Exposure Near the Three Mile Island Nuclear Power Plant, Ralph E. Shuping

• This document may not be used for publication, except for used in government publications, without the express written consent of the author.

Y 2

The purpose of the 8 samples taken some 50 miles away in Maryland was explained by the author as " control films which had elevated fog levels".

The HHS study defined the dose response to the sample films as 0.025 net density (ND1 per 4 mr exposure.

The HHS study made no effort to quantity the effects of time and temperature on ND. It did not consider sheilding effects.

While acknowledging, quite reasonably, that the study was "not sensitive enough to establish the actual exposure at the site of collection",

the author leaps across logic and asserts that it "does rule out exposures much larger than those predicted by the Ad Hoc Population Dose Assessment Group."

The data can be enlightening. The author assumes that the ND's of the

' Maryland samples are the result of non-radiation induced effects. He then concludes that all of the Pennsylvania data is free of radiation effects.

(See p. 5 HHS Publications) Nowever, the author then goes on to note that 133 film exposed to a distributed source of 2.7 mr Xe distributed source exhibit a noticeable cyclical pattern and that one of the samples (Middletown) exhibits such a pattern. The author thn points out that at least 4 mr was needed to produce such a pattern. He then equivocates on the basis o.f the ,

not high Maryland data (attributed to bgg / demonstrated to be caused by natural aging) and admits that he doesn't have the foggiest idea of what's going on by concluding that "it is possible that the periodic patterns on the film may

~

2/

have been caused by thermal fogging , natural background radiation or maybe oniv an artifact." (Emphasis added.) Clearly this study is meaningless due to exceedingly inadequate methodology.

2/ which is not cyclical in nature since thermal exposure is uniform!

. .+

3 n'

The significance of this failure to pursue a potentially fruitful approach to dose assessment can be seen by examining affidavit 5 of the-3/

Aamodt study.~ The signator, a dentist, attests to the fogging of oral film stored behind a cinderblock and gypsum wall within his office on March 28 and 29. Beginning on March 30, when he first became aware of the fact that an accident had occurred at Three Mile Island, he posted new film outside his office each day for a week. No fogging occurred.

The dentist also points out that on March 28 and 29 he experienced a metallic taste, a " queasy" stomach and a generally " funny" f aeling which he related to his receptionist. On March 28 and 29 he "had no knowledge of the accident at TMI."

Any reasonable mind would infer that the dentist and his oral film

~

suffered a radiation insult in the March 28/29 timeframe. It is a fact that the early release (s) from TMI-2 passed in the general direction of the dentist (NNW). It is not unreasonable to infer that these releases were of a magnitude to cause the effects the dentist swears occurred.

Had the RHS study been a serious and responsible attempt to accurately determine the doses attendant to the TMI-2 accident, this dentist's data would have been considered with all other appropriate data availab,le in the ,

TMI environs. Rather, HHS relied on the Ad Hoc Committee's (unjustified) finding that population dose was negligible and provided one more unjustified paliative to the concerns of residents of the TMI area.

~ _ -

2/ Attachment 3, Aamodt Motion of January 15, 1985

r-r i

This is to certify that the document AAMODT MOTION ,

FOR RECONSIDERATION OF COMMISSION ORDER CLI-84-22 AND 'l'% -F ' i OPENING OF A HEARING was served on the Commissioners, ' 'f idII

the Boards and the Parties by hand-delivery *on January 15, 1985 or by deposit in U. S. Mail First' Class.

f i . LAL4 f t'd i~ 41 8 '

Ma'rjorie/ h. Aamodt SERVICE LIST

• Nunzio J. Palladino, Chairman

• George Trowbridge, Esq.

U. S. Nuclear Regulatory Commission Shaw, Pittman, Potts &Trowbridge Washington, D. C. 20555 18 0 0 "M" S t . , N. W.

Washington, D. C.

• Thomas M. Roberts U. S. Nuclear Regulatory Commission Washington, D. C. 20555

• James K. Asselstine U. S. Nuclear Regulatory Commission Washington; D. C.

• Frederick M. Bernthal

-U. S. Nuclear Regulatory Commission Washington, D. C.

• Lando W. Zech, Jr.

U. S. Nuclear Regulatory Commission Washington, D. C.

cketing & Service Branch U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Jack Goldberg, Esq.

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 TMIA 315 Peffer St.

Harrisburg, Pa. 17102

• Ellyn Weiss, Esq.

Harmon, Weiss & Jordan 2001 "S" St., N. W.

Washington, D. C. 20009 Thomas Au, Esq.

General Counsel Offices Commonwealth of Pennsylvania Harri-burc, Fa.

>