ML20113H858

Table of Contents & Errata to Aamodt 850115 Motion for Reconsideration of Commission Order CLI-84-22 & Opening of Hearing & Table of Contents & Errata to Motion Attachment 3

ML20113H858
Person / Time
Site:	Three Mile Island
Issue date:	01/22/1985
From:	AAMODTS
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20113H838	List: ML20113H837 ML20113H858
References
CON-#185-250 CLI-84-22, SP, NUDOCS 8501250342
Download: ML20113H858 (10)

Text

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TABLE OF CONTENTS AAMODT MOTION FOR RECONSIDERATION OF COMMISSION ORDER CLI-84-22 AND OPENING OF A HEARING E382

1.0 INTRODUCTION

...................................... 1 2.0 BASES FOR COMMISSION RECONSIDERATION OF CLI-84-22 .. 4 2.1 Significant New Information . . . . . . . . ... . . . . . ........ 4 2.11 (Verified death certificates and population base)... 4

-2.11-(Recently proferred testimony of David Gamble)...... 4

'2.2 Gross Errors ...................................... 5 2.2,1 (Dependen.ce on biased information provided by Staff). 5 2.22 (Dependence on Centers for Disease Control review).. 6 2.23 (Ex-parte communications)........................... 6

- 2 4 (Dependence on official investigations . . . . . . . . . . . . . 6 30 BASES FOR REOPENING THE HEARING .................... 7

.1 (Discussion of Section 2.1 as it relates) .......... 7

.0 DISCUSSION ..........................................-8 4.1 The Commission's Conclusions Concerning Validity o f Aam od t S tu d y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

- 4'. 2 Deficiencies in the Comunission's Conclusions . . . . . . . 8 4.21 Previous Scientific Surveys ........................ 8 4.22 The Aame,dt Study ....................................i11 4.23 The CDC'2esponse ................................... 13 4.3 The Commission Has Erred ........................... 13 5.0 . MOTIONS ............................................ 14 5.1 (Motion to reconsider decision CLI-84-22) .......... 14 5.2 (Motion to reopen a hearin8) ....................... 15 Attachment 1 - AAMODT MOTION FOR EXTENSION OF TIME TO

-FILE MOTION FOR RECONSIDERATION OF ORDER CLI-84-22

. Attachment 2 - Letter of December 28, 1984, Mart'in G. Malsch to Marjorie M. Aamodt Attachment 3 - THE THREE MILE ISLAND ACCIDENT, AN INVESTIGATION OF.THE EFFECT ON THE HEALTH OF RESIDENTS AND FLORA IN THREE AREAS WNW-AND SW OF 'IMI by Marjorie M. Aamodt Attac'hment 4 - Exhibit 7 to Gamble Testimony-Attachment 5 - Chronological Bibliography, STATUS.0F RADIOLOGICAL IMPACT' STUDIES ~FROM'THE AC.CIDENT AT THREE MILE ISLAND .

. APPENDIX A - CRITIQUE 0F CENTER FOR DISEASE CO 0]; RESPONSE TO AAMODT STUDY APPENDIXB'-THETHREEMILEI'LANDACCIDENT,Uk,4PPHOTOGRAPHIC S

FIIR FOR DOSE' ASSESSMENT >-

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8501250342 850122 s PDR ADOCK 05000289 C PDR 4

ERRATA

-AAMODT MOTION FOR RECONSIDERATION OF COMMISSION ORDER CLI-84-22 AND REOPENING OF A HEARING Page 2, line 13 - Change " December 21, 1984" to " December 20, 1984". ,

line 16 - Delete. Insert "have chosen is that the Commission filed its order CLI-84-22 in the docket of the Restart Proceeding.

Page 3, line 15 - - Delete "than" after "unless".

line 22 -

Change ".the Staff criminal actions" to "the Staff's criminal actions".

Page 4, line 4 - Add "," after " cancer mortality rate".

line 22 - Change "Mr. James Gamble" to "Mr. David Gamble".

line 24 - Change "in Attachment 4" to "in Attachment 4 (see page 15, lines 8 - 12.)

.Page 5, line 11 - Delete " dose".

line 14 - Change "," to "." and change "for instance" to "For instance,".

line 15- - Add "," after "73".

line 16 -- Add "," after "public".

line 22 - Change "NNW" to "WNW".

line 23 - Change " lay in" to " lay near or in".

Page 6, line 10 - Change "pa es" to "pages".

• Page 9, line 4'l - Change 't88" to "18".

line 9 - Change "priveleged" to " privileged".

Footnote - Delete " " after "early" (line 2).

Page 10,11ne 3 - Change "releif" to " relief".

line 5 - Add "," after "which".

line 6 - Add "," after "sure".

line 16 - Add "," after " readings". '

line 17 - Add "," aft'er " direction".

line 18 - Add "," after " referred to".

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-Page 12, line 1 - Add "," after " simple". ~

line 5 -

Delete "6_/" . -

l Page 13, line 5 - Add " indicating the shallowness of the CDC review" after

! "the Aamodts".

! line 9 - Add "," after " correct".

line 10 - Delete quotation marks around " scientific".

line 24 - Change "77" to "6/". . .

Footnote- Change "7/" to "6/".

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4 Page 14, line 11 - Change "4.0 M0JIONS" to "5.0 NOTI'ONS".

line 12 - Change "4.1" to "S.1".

Page 15, line 1 - Change "5.2" to "5.1". -

line 3 - Change " north north west" to " west northwest".

Delete " south".

i Appendix A, Attachment- Page 2 of CDC letter provided.

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ERRATA (2)

AAMCDT MOTION FOR RECONSIDERATION OF COMMISSION ORDER CLI-81+-22 AND REOPENING OF A HEARING Attachment 4 - Add pages.14 and 15 of Exhibit 6, Gamble testimony (Another version of document "Reportability of a Predicted Offsite Exposure Rate").

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t (To be added to Attachment &) 1 Pages 11+,

15 - Exhibit 6 of i Gam ble Testimony

("Reportability of a Predicted Offsite Exposure Rate")

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.. ,t VOIG: There was?

. VOIG: ,

--released when the incident first occurred.

, VOI G: Yeah, I heard somebody, I guess on the radio,-f think it . .,

wasfromtheBureau,sayingthattherewerb10Rperhour, out the cooling tower. ,

VOIG: No.

VOIG: Was that emergency services?

VOIG: I don't know who said that.

VOIG: It was somebody from the State of Pennsylvania being inter-viewed, that's what.

It is unlikely that the lice.nsee inadvertently omitted the 10 R/,hr pre-

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diction when~ describing the accident.to Region.'I-after 0750. Clearly, from the Crawford and Dubiel statements,,the ,Iicensee wanted not to believe the done monitor and Crawford's calculation.

The licensee not only. failed to report the 10 R/hr prediction to Region I, but also, according to the following statement of Thomas Gerusky, Director of the Bureau of Radiation Protection, countered the report to BRP with nonexistent Goldsboro survey results.21/

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. 4 In the meantime, 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, we 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 measurement to partially achieve such disproof also is understood. The use of nonexistent offsite survey results to further disprove the pre-diction is not understood'.

. Conclusion .

Nothing discoyered in this investi,gation relieved the licensee of the requirement to report to NRC iall pertinent facts concerning the accident.

The 10 R/hr prediction seems not to have been adequately disproved by 0750, when telephone c6ntact was established with Region I. The dec'sion-i 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 method: described in Radiation Emergency Proced're u 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). .

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• r-TABLE OF CONTENTS THE THREE MILE ISLAND ACCIDENT AN INVESTIGATION OF THE EFFECT ON THE HEALTH OF RESIDENTS AND FLORA IN THREE AREAS WNW AND SW OF.TMI EBS' Foreword 1.0 ABSTRACT ......................................... 1

2.0 INTRODUCTION

..................................... 1 3.0 THE HEALTH SURVEY ................................ 2 3.1 METHOD ........................................... 2 3.2 RESULTS OF THE SURVEY ............................ 4 3.21 CANCER MORTALITY RATE ............................ 4 3.22 CANCERS AND TUMORS IN LIVING PERSONS ............. 6 3.23 CANCER / TUMOR CLUSTER IN FAMILIES ................. 9 i 3.24.0THER HEALTH EFFECTS ............................. 10 3.241 (Pregnancy effects) ............................. 10 3.242 (Skin effects) .................................. 11 3.2 2 .(" Ruptured / collapsed" organs) .................. 11

3. STATEMENTS CF RESIDENTS WHO EXPERIENCED EFFECTS MOST REASONABLY ATTRIBUTED TO EXPOSURE TO HIGH-DOSE RADIATION ....................................... 12 4.0 RADIATION EFFECTS ON PLANTS ...................... 15 5.0 DISCUSSION ....................................... 16 6.0

SUMMARY

.......................................... 19 Figures 1 -

DEMOGRAPHIC CHARACTERISTICS OF AREAS SURVEYED .3 2 - CANCER MORTALITY RATE ANALYSIS FOR THREE AREAS WEST OF TMI .................................. 5 3 - VERIFIED DEATHS LISTED CHRONOLOGICALLY ......... 7 4 - CANCERS.AND TUMORS IN LIVING PERSONS ........... 8 5 -

CLUSTERS OF CANCER DEATHS AND CANCER / TUMOR

- DIAGNOSES IN FAMILIES ......................... 9 .

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" COLLAPSED / RUPTURED ORGANS" ............'....... 12

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SUMMARY

OF UNUSUAL EXPERIENCES ON MARCH 28-30, 1979 REPORTED BY RESIDENTS WNW OF IMI .............. 14 Affidavits .- All identifications of names, straiets, addresses expurgated.

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Attachment 1 - NEONATAL' HYPOTHYROIDISM CASES, LANCASTER COUNTY, 1979 - 1983 APPENDIX A - RATIONALE FOR DERIVING BASELINE CANCER MORTALITY DATA F.OR THREE AREAS SURVEYED WEST OF TMI

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ERRATA

. THE THREE MILE ISLAND ACCIDENT AN INVESTIGATION OF THE EFFECT ON THE HEALTH OF RESIDENTS AND FLORA IN THREE AREAS WNW AND SW OF TMI Titlepage, title - 3rd line - Change "NNW" to "WNW".

' Page 1, line 5 - Change "is" to "are".

line 8 - Delete "to five". Add "from five".

line 8 - Add "," after " areas".

line 9 - Add "," after " geographically".

Page 3, line 22- Add "," after " followup".

Page 4, line 7 - Delete " accident and none that were diagnosed prior to this time". Add " accident.".

line 14- Change "occuring" to " occurring".

line 17- Change " north northwest" to " west northwest". Change "about

&l8 10 miles from TMI," to "in a line with surveyed areas 1 and 3,"

line 28- Add "," after "(1978)".

Page 6, line 1 - Change "stastical" to " statistical".

line 8 - Change "is" to "are".

line 18- Add " finally reported" after "one case was".

line 19- Change "was due" to " appeared due".

lines 19 620- Delete "if it became known by the employer". Add after " career" "or other plans."

Page 9, line 6 - Change "was" to "were".uDelete "for.each family group was made within six months." Add after " diagnoses" "within a family were made no more than six months apart.

line 13- Change "errythema" to " erythema".

line 16- Add after " interviewers." "Where one person was outside, the hypothesis is that this person carried radioactive particulate material into the house and, in this way, those persons who remained indoors were impacted."

Figure 5 -Case 1 - Add under Affliction " Lump" - before " Vocal Cords" and " Lumps" before " Shoulder, Spine".

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Page 10, lines 19 Deletethesentencesbeginningwith"Thereportspf C sections" and ending with " Health Departacst.y Replace with "The number of C sections suggest an area of investigation that was eliminated by design from the pregnancy outcome HealthDepartment.gpudyundertakenbythePennsylvania

. . J Delete ',' time.che distanco i(My ime " to the end of t,he

'Page 11, lines 7-9 -

g sentence. ,s >

Replace with "with the amount of radiation released from TMI."

line 11 - Add "*" after." quantify.". Add footnote:"* Not all ,

categories that now appear important were included in the intdeview."

- line 12 - Change "errythema" to " erythema".

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ERRATA, contd.

Page 12, Figure 6, last entry - Change ":'!.~a'" to"WNW".

Page 13, lines 1, 2 - Delete.

line 6 - Delete "1" between "1" of "all" and "o" of " occurred".

line Change "Errythema" to "errythema".

Page 14, Figure 7, Title, 2nd line - Change "NNW" to "WNW".

Page 15, lines 10,11 - Change "NNW" to "WNW".

Page 16,'line 7 - Delete "at least".

Page 18, line 23 - Delete ""done" and insert " arrived at",

lines 26, 27 - Delete beginning at "The assumption" to the end of page.

Add "The assumption of no exposure following the specific period in 1979 of the TMI-2 accident to accident-related radiation is not supported by our" Page 19, line 10 - Add "from the high post-accident incidence"4/ after "expe Bottom of page - ged incidence".

Attachment 1, NEONATAL HYPOTHYROIDISM CASES, LANCASTER COUNTY 1979-1983

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. s. Attachment 1 NEONATAL HYPOTHYROIDISM CASES, LANCASTER COUNTY 1979 -

1983 Year Number

, 1979 ............... 7 1980 ............... 4 1981 ............... 2 1982 ............... 0 1983 ............... 1

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