ML20126G665

Group of Ltrs Re Facility Restart.One Comment on Proposed Rules 10CFR30,32,70 & 150 Re Smelted Alloys Encl

ML20126G665
Person / Time
Site:	Crane
Issue date:	03/16/1981
From:	Keenen B, Phillips J, Pierno J AFFILIATION NOT ASSIGNED
To:	Ahearne J NRC COMMISSION (OCM)
References
FRN-45FR70874, RULE-PR-150, RULE-PR-30, RULE-PR-32, RULE-PR-70, TASK-OS, TASK-TP-710-1 45FR70874, NUDOCS 8103300389
Download: ML20126G665 (95)

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Dear Mr. Ahearne,

I a= writing to urge the restarting of the (undamaged) Unit 1 reactor at Three Mile Island. Dr. Carl Lunden of NASA has raised a cuestion of whether or not it is moral to restart the unit in, light of the local success chat hysteria fanning organizations have enjoyed. I contend that this depends on the fundamental value. upon which ones morality is based. If we take =an's life to be the i standard, then it follows that the unit ought to be restarted at once. The facilities which are substituting fer the unit pose greater relative hazards to the public than unit I ever could. The unit 2 plant at Diablo Canyon is another exa=ple of the sort of unnecessary delaying which tends to cresent a greater public risk than the power plant itself. Failure to produce, es-pecially failure to electrify, will (I believe) result in a net lowering of our GNP which in turn (I believe) will lower our life expectancy. This is much ignores but the correlations are too clear to be accidental. Impediment constitutes just as real a health risk as irradiation. Even conservation neasures have been shown to routinely trap encugh radon in the home to cause a greater increase is background radicactivity in living space than what the Cor=issics allows g outdoors around a nuclear plant. ) I would greatly appreciate the inclusion of these factors in future licensing deliberations. No one can deny that decreasing our dependence en foreign oil supplies will decrease the likelihood of cur getting involved in hostilicies abroad. Thank you for your time and attention. Ccrdially, g,g i tt e ., 1 - g N

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Dear Friend:

g We offer our heart-felt thanks to you. Your generous contribution to the d* Mile Island Legal Fund has enabled us to carry on ene of the most important fights against nuclear power. Two years after the accident, the press no longer considers the story of the ac-cident at Three Mile Island to be headline news. Yet, we face a situation that is perhaps even more grim than ever before. The clean-up of the highly radioactive damaged Unit 2, once projected to take 4-5 years is now expected to require a total of 9 years! And, while the residents of this area must cope with the continuous stress from living in the shadow of the still dangerous reactor, Metropolitan Edison is moving toward' restarting Unit 1, the twin of the damaged reactor! We believe that Unit 1 should not be allowed to restart, and we have spent thousands of hours in hearings before the Nuclear Regulatory Co:miission. Despite the testi-many from many experts that the plant should not be restarted, the president of General Public Utilities (the parent company of Metropolitan Edison) has requested that the NRC allow the plant to restart before the hearinas are completed. We have learned, as in the case of the venting of the radioactive krypton gas last July, that the util1 ties and the NRC often ignore the process of public hearings and proceed to do whatever they want to do without restraints. In the case of the krypton venting, the NRC allowed Metropolitan Edison to release the krypton gas into the atmosphere without a notice and hearino as reouired by statute! The court later stated that the venting without a hearing was illegal, but the pronouncement was made a#ter the radioactive gas was already vented! We fear that the same type of action will again take place, and that once again our human rights will be violated. On other fronts, our fight to prevent the dumping of 700,000 gallons of radioactive water into the Susquehanna River (which is the source of drinking water for many residents) also continues in full force. It is possible that the fight surrounding this issue will reach the Supreme Court level. If the Supreme Court agrees to hear the case, it will mean an enormous expenditure of funds for preparation of extensive legal briefs, -- necessary in presenting our argument. -cont'd-W7 AA 6t*'l AV CTOCCT LJ A COICDI ICC CCMMCVf UA MI A 1 71tY2

We nes ycur help. Your warm su pert has been an inspira:icn :: many a weary velur:eer, anc cur small, cut dedicated staff. Your genercus financial succort has ace it possible fer cur coalitien cf greu:s* to carry en frcm day c cay. N:v.,.:>:ever, we mus "ntensi'y cur efferts even mere. Tc :c so, we neec #inancial hel:. The nuclear industry has cienty cf =cney for tneir lawyers, but we must Oe;er.: u;cn Our cwn c0n:ributiens and these of pe0;1e such as you. Many cf us nave ;i.'er. cf cur cwn perscnal resources, as well as our time, anc we mus: turn tc y0; ence again fon hel:. We are not cnly fignting for our safety -- we are esta:lishing precedents that may help others -- if :nere is ever another accident in ancther part of the country. We ask.ycu cnce again to assist with a centribution cf SE5, $15, 550, 5100 cr wna a.er you can aff:rd. Ycur help makes a big difference as we figh ne nuclear industry. Sincerely ycurs,, Qr D' Ocnald Konkle President Three Mile Islane Legal und P.S. Tne nuclear industry and its su::cr:ers are ficcding the Nuclear Regula: ry Oc=missien witn le::ers of support for the restart of Uni: 1. We nink i; is im:cr: ant for the NRC to hear from people who :elieve that Unit 1 should 90 be restarted. If you share this view, we encourage you to write to the NRC expressing your opinien. Your letter will help cur cause. The address is: Mr. John Ahearne, Chairman U.S. Nuclear Regulatory Commission Washing:cn, D.C. 20E55 'The Three Mile Island Legal Fund Coalition includes the felicwing groups: THREE MILE ISLAND ALERT, Harrisburg PECPLE AGAINST NUCLEAR ENERGY, Middie:cwn NEWBERRY TOWNSHIP TMI STEERING CCMMITTEE, Newberry Township SUSCUEHANNA VALLEY ALLIANCE, Lancaster ANTI NL LEAR GROUP REPRESENTING YCRK, York ENVIRCNMENTAL COALITICM CN NUCLEAR F0WER, State College m.

I s 1 Reprinted from E if 2 0$01160 X Friday, March 28,1980 js /\\ ~ G ' r) f ) A 9 One year after TMI, and danger remains By EDWARD J. MARKEY Shortly after the reactor at Three Mile Island The absence of approved evacuation plans report. That figure was deleted in the final ver-went havwitc a year ago today, a team of radi-was starkly evident in the disorganized emer-sion, but they did enticize the 10-mile limit as ation expens was sent from Washington to gency efforts during the TM1 accident. Al- " inadequate." prepare an evacuation plan for a 20-mile radius though light water reactors cannot explode like One year after TMI. there are still.tl existing around the stncken plant. No workaoie evacu-a bomb, they do contain over 1000 times the plants m 16 states without federally approvec ation :!an existed for the people in neighbor-radiation of the Hiroshima bomb. If the reac-evacuation plans. There are 12 more plants in mg communnies m the cent of a serious acci-tor's concrete containment were ever nine states without approved plans seneduled dent. Fortunately, the runaway reactor was breached, radiation could spread across the to go into operation by the end of 1931. brougnt under control and no general evacua-countryside like a rain of death, poisoning Congress, like the NRC, has fa!ied to move tion was requtred. large areas downwind of the plant. vigorously in the past year to upgrade safety at Have the glanns safety deficiencies revealed Evacuatica plans are crucial buffers against existing reactors. We are still considermg one year ago - such as the absence of emer-death and injury. If half the Strontiurn 90, whether to lint the operation of new and exist-gency plans - been corrected? What have we Cesium 137 and other radioactive isotopes in ing piants to feceral approval of state emer-accompitsned in upgrading safety at our exist-an average reactor were scattered by the w1nd, gency plans. mg nuckar plants? a lethal doce of radiation could be delivered That issue is now before a House <5 enate . Response to TMI seems to have been charac-within fourhours to everyone ins.Je an area six conference committee as an amendment to the tenrec more by paraiysis than by aggressne miles long and one mile wide. 1980 SRC budget. Will a majority of the con-act:en. Two major studies of the accident inde-That area could double within 24 hours and ferees decide to demand fecerally.tpproved pendently concluded that the Nuclear Regula-eventually increase to more than 50 milea emergency plans as a cordition of licensing tory Commission (NRC) cannot. with its pres-downwind. Unless evacuation were begun in nuclear piants? en: staff and a:::tudes, guarantee the proper advance of the radioactive " plume." peopie The American Nuc' ear Energy Council and ae; tee of safety at our ex: stir.g plams. would receivelethal doses of radiatien. others in the nuclear industry oppose this step. Yet one year later, the staff of :ne NRC re. In the past, the NRC only required the util-So does the Carter Administration, whic mams intact. No commissioners or top staff ity to outline how a few people - mamly those would leave the maner to tne NRC. Nuclea-na.e been fired for TM1 er related reasons, at the plant site - wo%d be evacuated. State proponents threaten to kill the legislation wnen Sencus safety proolems remam ignored. Oper-plans to evacuate people inside a five mile it returns from the conference committee ann; plants base not been carefully reviewed. radius around each plant were voluntary and unless it is shorn of even a compromise version Tne licensing procedure still does not permit not required to conform to federal guidelines. of the emergency piannmg language. Other an exammauon of tne consequences of a re-in December Massachusetts civil def ense phm fundamental issues have not even been iease of radianon from a plant. nets suomitted plans on how to evacuate with-addressed by Congress and the NRC. An acnon plan for TNI-related safety im-in a 10-mile radius of the Pilgnm plant in The American Nuclear Energy Council calls prosements has been drafted by the NRC Plymouth and the Yankee Rowe plant east of tougher safety standards - like requiring staff. But the majonty ofits recommendations North Adams, approved evacuation plans - a " guillotine" will not be impiemented for months or eves But many experts believe that evacuation for nuclear power. The real guillotme is the years. The moraronum on licensing new plants inside a 10-mile radius may not be enough. danger of nuclear accidents and the absence of has been lifted. In sum. we see a return to Even during the TM1 accident, evacuation was credible emergency plans to cope witn them. l " business as usual" by the NRC, almost u if being considered for a 20 mile zone. The the accident in Pennsylvania had never hap-Rogovin panel - an independent probe of the Edward 1. Afarkey er a Democratic congre:s-pened. NRC's actions during the accident - consid-manfrom Afassachusetts and a member of two cred calling for a 30-mile radius in their draft House energy subcommines.

a f \\ Reprinted from THE PATRIOT EVENING NEWS Rcp tnted from THE PH11 ADELPHIA INQUIRER Monda), July 21,1980 Wednesday, June 18. 1950 a d O n t&S.y .a As a result of filtenng the contaminated ~ water, the EPICOR filters, called " spent resin C T-a-Ca-liners," are contaminated primarily with cesium 137 and strontium 90, two of the most On .aC5mo O dangerous radioactive elements. f }* Q*h ' {yg1 If released into the outside environment, BALTIMORE (UPI) - Government offi-both elements would be likely to become a part cials do not know precisely how much radia- -g of the food cham that leads to man. Cesium tion escaped from Pennsvivania's Three Mik d c an l9 9 [s pjemises v yt de

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Tg }]' Strontium 90, whose rad:oactive half life is 26 long term impact,it was reported Sunday. The Baltimore News American, in a copo years, tends to accumulate m the bones. No licensed waste d3posal facility m the righted article, reported a three-month invesi: e unny take wastes is hot, sai $ation showed feceral and state agencies has Kohr, an attotney for the alhance.,d Jean Bv Mark Bowden These failed in their response to last year's acciden: U William Ecenbarter aGm smr wmm elements, if you dnnk a glass of water that The newspaper charged: comams them.,will be:ome bonded to the -More than one year has passed and n. An anti-nuclear group filed a complaint in d hnot .o es s and government agency has been directed to inve: federal court yestercay charging that extremely cyQ tigate possible long term environmem o .,8.. hacardous nuclear waste matenal is bemg sE damage resulting from the accident. [yjad stored unsafely at the Three Mile Island -Requests by farmers for examinations a nuclear power plant. spent fuel assembl.ies, which are bem.s stored d sessed and dead animals after the accider In a complaint filed in Harnsburg with U.S. on site at operating nuclear power plants have been ignored. Middle District Judge Sylvia Rambo, the Sus-around the country. This form of storage is -Despite his pledge to determine the cons; quehanna Valley Alliance, a group based in the being allowed pending the establishment of a quences of the accident, Pennsyivania Ge-vic:nity of TMI. argued that a water filtration na onal nigh-le e nuc e waste bun sit ' Dick Thornburgh is unable to name a sin; h agency or person conducting any studies. system called EPICOR : had turned the plant mto a "high !csel waste dump. late 1980s. The News American also said federal an The EPICOR system has been Gltering state officials acknowledge they cannot gau; radioactive e!cments out of mildly contami-precisely how much radiation escaped from tr cared waste water left from the Maren 28, plant, located 45 miles north of Baltimot 1979, accident at TMI. As a result, the filters because they did not have adequate equipme: themselves have becc>me contaminated, and it on hand when the accident occured. is these used filters, now being stored at the "There are still some questions of just he plant, that the alliance says pose a safety risk. much I 131 (radioactive iodine) was releas: Tom Elsasser, a spokesman for the federal early in the accident.. We don't know if the Nuclear Regulatory Commission (NRC), said were orner releases early on, other than fre the filters were being stor9d in a special con-the stacks," said Thomas L. Gerusky, chief crete bunker that is Good proof and thus com-the Pennsylvania Bureau of Radiation Prete pletely safe. tion. The alliance's complaint was amended to a The state's Emergency Management Agen lawsuit the group filed last year ;;ainst the found it was unprepared to evaluate what w NRC and Metropolitan Edison Co.. operator , leaking from the nuclear plant because of the nuc!!ar plant, asking that no EPICOR. radiation-detection equipment was incapat treated water be dumped into the Susquehanna of picking up the type of radiation release River. That lawsuit is waiting to be heard by the newspaper said. Judge Rambo,

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w~ DOCXET NUMBER M A UI A FAC. 8 N T Y.. b 130 Brown Avenue, Prospect Park-Paterson, New Jersey 07508 March 2, 1981 The Honorable Victor Gilinsky Commissioner U. S. Nuclear Regulatory Commission Washington, D. o.

Dear Commissioner Gilinsky:

This correspondence is in reference to Docket No. 50-2895? concerning Three Mile Island Unit #1 of Middletown, Pa. It is a fact that Three Mile Island Unit 1, now closed by the Nuclear Regulatory Commission, was not involved or damaged in the accident at TMI Unit #2 in March of 1979. Moreover, a poll taken last spring in cities near TMI indicated that in excess of 585 of the residents favored restarting the undamaged reactor. Since the incident, the U.S. electric power industry has responded quick..y and forcefully to correct inadequacies in-dicated by the accident. Those corrections have been and are now being made at the undamaged unit. As a result, this unit, like plants elsewhere, is even safer than it was before it closed for routine inspection and refaeling way back in 1979 Moreover, it is ccsting Metropolitan Edison and its custcmers nearly $500,000. a day : That is, $500,000. da31y to purchase more expensive coal and oil instead of uranium for use as fuel. Please lets get Three Mile Unit #1 back on line as soon as possible. h f $f[3 CWm.cc D m:nt 2,y Thank you. y w t-- Verytrulyyoursp.G.v;'[3$/yc $ pac 2,750/chcEEW~ \\ Vincent-A Maras)(e-g.g y .. m.e4 m g N I $ 2 QOD t'm. MAR 1 e jggg, q- [_ "--- ' g'- q am '. m :.a :,.,,s a%com u. / Er neh -~ /, y. 6

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. JIM TASZER ' DOCKET NU.MBER fB00j,UIIL fAA9.5.h.*e21.(.% W WO M M ONS '2Cm.feb afale.s Senale - -.an - - ,..,m. s=4w. sustusas WASHINGTON, D.C. 20S10 March 4, 1981 Mr. Carlton ymmerer Di. e. 4 office of ce2,.ssional occ a to Affairs ~ umec p,- wtcry e-4 --4 m 7 MAR.161981 > 1717 ' Street, N.W. 7;, d m h g gj/ Washiston, D.C. 20505 g N

Dear Mr. Kammerer:

4 Recently I was cer:tacted by St:t. art L. W'f Wiq ~ the shutdown of 'Ibree Mile Island LTdt 1. A ccpy of that ecrm:nication is erricsed. Any c::r:ments er infc=atien that ycc my 1:e able to provide wen 2d be very nu:h accreciated. ?muc you for ycur time and attentien. Sincerely, s SM tiited States Senater / W1e=u: e M.:. .~ ) l ~

.~ occm uuuea p on,a_uit rac f a : M i. Ziaad.!. $ck& i ^ 1,9y,,,,,ng,w.,, -1 j Mwpa!!a,1ee $710/ FEs & W1 4 4 ! ooCKETED p usse . he %. c=me.a,,.,. Sauu., MAR 16193{ > n ~ 7; % sell h ildh, cm:n of the sacritory 9 Docketing & Sergcn 2ad.ington, D.[.205/0 ~ Doeket 50-2??, Jr& Unit I, niicletoc., M /(9/ m I w" Dean Su. : St ha.1 come to my atlmt.Lon, and S wish to c:!.L LL to youas, that our yovernment dat. doun, and has kept shut. doar., Jkree-?dle Saland Unit /, which ac not involved in, nor damped by, the accLient U t knocked out UnLL 2 neaaly tuo years ago. Unit /, S am told, k esserm!!y Like many other nucleax plands around the couning, for cl.L of witch modification.: were ondexed aftes the accident. ."'hese pl.=nts continue to produce powv., without creathy problems, while the modi-L aenaLu tie =tions are being ude - escept for Jhaee ALLe islard Unit I, whic dut doun, producing now powe.n, aLLhough the modification.1 have been mde.11at k Us !.oyic of Ois situation? Si costs net.aopolitan Edkon and it.s cust.omm 1500,000 a day ext.a la buan coal and oLL instead of using usaniwn. Shuttky c'oun and keeping shut doun a plant dat ha.1 not been. damped, and yet has been ma's safer than it ac.s pas-viously, l.coks Like duenLr.iration in me. !sn't t.hk another case of buseauanatic ovu. kill? Os k it some kind of punkhme..G "forth noLL.; k a poll laken Last mn near JhazeALle Spring dat indicated 58 pexcent of the. aesidenta in e Esl.and favored anatart.ing the undamaged reactor. WLLh the US'rK kolding heasings on aeslaating 2:S-1, the membera nee.d to beas in mind U.at (/) nuc ear powen k. safe, inexpensLve, and needed; (2) JFS-/ 1 k diffaaent (som JfS-2; (3)'JFS-/ ha.r been modi! Led and dou!.i be restarted with-out del.=y; and (4) Ue AK has acited too 1.ong aLaeady to resolve Ue fate of 273-Sinceacly puas,

R E f- _ - ' ~ ~. 73.4 f C- __g_ . - - AL7 cys m. l _;- :, g g g ;3 s em tA. 3.D* 7s Box 329 I y,';6 I he tmNR~ g' Gettysburg, ?A 17325 Q iG 1gp, '12 ~. ~ c-March 9, 1931 (C / 8 9

Dear u.a.c.,

I have just learned that you are in the process of deciding to recycle radicactive contaminated netals into general use netals. i I would like to sa7 personally that such a plan is eenple:ely un - acceptable.

• he additional cancer to fcundr7 nen, nachinists, and censumers of the products would be plain ne der.

I would like to i have a full copy of this ridiculous proposal. l j 3econC7 I want to state ny opinion of the re-opening of the TMI unit one plant as a nucleer pcwer plant. '"he unit should be changed to a conventional power plant for safety and high effielency. Unit ene could be changed to coal, weed chips, or cenpressed : arbage pellets fren nea.-.by towns and cities, %uelear plants are approri, ate 17 fifty percent less efficie'nt than eenventional~ fired genersting plants. because the stean te==erature cannot be brought up to the high super j heated stean of conventional pcwer plants. I fai1~to feel safe'ih. living near a nuclear power ple: t due to the fact $at the reactor vesse are carben steel which nelts at 2c00 degrees ? and the nuclear fhel in I i-1... I an uncontrollable situation of loss of coolant will heat. up to 12,000 4 degrees ?. That is four tines the nelting poinW'.'of cam.en or stainless steel. Could you please send' a list of proposed safety changes of I would also be interested in the environnental impac study Uni: One? of the : lean-up of !MI unit two. e4 p t,, @L 'A

DOCKET NUMSER / d40.D.,(UI!L FAC k'.h.)...,_ s Jeanette Pinder 212 Atkins Avenue Wilmington, DE 19805 March 9, 1981 U. S. Nuclear Regulatory Ccamission Washington, D.C. Ccamissioners: The f ar t that the restarting of TMI Unit 1 is even being considered seems ludic.rous to me in view of the fact that Unit 2 is full of radio-active mat.erial and no one knews when - er even if - it will be cleaned up. Residents are obviously opposed to the re-start because of Metropolitan Edison'a lack of credibility and because of fea s which are ecmpletely justified. I share these rears even though I live sixty miles away. The eighty nine incidents should not be taken lightly, since'it was a series of incidents such as these which caused the nese melt-down. Sincerely, @ !- 19p MLLL U DChMD \\ 13 s. uaxne MAR 161ggy, >u. in ame,,1m,, & 0%:ing a S 879 ./ / ca

/ DOCXET NUM3E2 Mb E D f@bkdT.f...,, _ 2455 George Washington Way E129 Richland, Washington 99352 March 10, 1981 Mr. John F. Ahearne Chairman, U.S. Nuclear Regulatory Commission 1717 H Street, NW Washington D.C. 20555

Dear Mr. Ahearne:

THREE MILE ISLAND UNIT NO. 1 NRC Decket No. 50-289SP The only reasons that TMI Unit 1 sits idle, bankrupting Metropolitan Edison, causing us to import mere foreien oil, and damaging the future prospects of the nuclear industry, are political. I'm a voter; you're a political appointee. So here's some political pressure in the other direction: Do your job and get TMI Unit 1 started! Thanks. \\I19) Sincerely, hb 9r M.! 61981, gf R. P. Musselman k d g$Nf w, cu i 1

DOCKET NUMatt JROD, & UTIL FAc.N. : N.i.,,.,,' 1707 Roeky Canyon Rd. Arlingtsa, Texas 76012 3/5/El John Ahearne, Crm. t;S :!uelear Regulatroy Cera21ssion 'dasnington, D.C. 20535

Dear Mr. Aiekrue,

For a long time, I, as is true for ma.sy Amerieams aerose the ecuatry have 'seem nore than a little someermee a'ocut, the entire Tree-P.ile Island muelear 71 ant aseiaent. Tareugs r.ricus scurses I try to keso un with 4evelepr.ents as your agemey ama others atte.pt to deal with the result of that tragis coeureuse. I usnerstama tha the :iRC is atter.pting to restar, cue of ;,he units at tue plant, aus I streng?.y urge you net, to ao so, 'out rather to join with other professicmala 12 isaust.7 a ad si,1:: ens /e xsumers to fixe a safer fer:1 of emergy. me Thank ycu, Kay Tae' eel / , a 9:n

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l Julia Corliss 4 / ?O Box 267 DOCKET NUMBC' Fairfax, Calif. 96930 ggyJ, yIILFE_g,, - r - _:f ~ w

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. U.S. Unclear ?.egulatory Com=. Washington D.C. 20555 tear Sir, I am writing to urge you and the other decisien makers at the

1?.C not to restart Unit 1 at Three Mile Island. The problems surreurding the clean-up at Unit 2 are =a=noth, as you obviously knew. The pecple who live in that area are feeling continual mental and anotiecal stress from the lurking threat of what they can neither see, taste, or s= ell ' radio-active centamination.

Fnewing that Unit.1 is shut de:m helps allay this stress sece. Do not start it up again, please. Also, I uculd urge you not to allow du= ping of 700,000 gallens of radicactive zater into the Susquehana P.1ver (frem Unit 2) because this is a source of drinking water for people ard animals, as well as a source of crop irrigatien. I also thi=k it was wrong for you (the l'?.C) to allow !!etropolitan F41 son to release krypton gas into the atmosphere without a notice and hea d ; as recuired by statute. This Wi25 a flapant violation. I knew you are under pressure to clean up, but you employ sene of the best brains in the cenntry. Surely, a safer solutien ceuld be arrived at. And if it can't, if there is no way to clean up without contaminating the enviren=ent with radioactive =aterials, then it is ti=e to re-evaluate the neral respensibilitf the nuclear industry has to the living things of this planet, plants, animals, and pe ple. Thank you for reading this letter. l l Sincerely, Julia Corliss 1 ? mw-e 4..,.n. ..,:i-.,... 7-gae-

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Dear Mr. Ahearne et al:

Docket 50-28cS?, SII-1 Middletown, Pa. It is a FACT that Three Mile Isla nd 1, noe closed b7 -he Occ:.ission cs not involved. in the accident at SII 2, neither was it ?a-aged. ?ne pec71e in the area have been polled and indicate that they want SE 1 restarted. Si~.iliar plants are being operated while :odification is going on. The f.ecision to keep the undamaged unit closed, is irrational, unfair a nd just another enample of 3eureaucratic Eungling. is costing Metro 2dison and it's customers to bu7 expensive Itcoal and oil, about 3500,000, per day. '.?cw he?.rin c will cost tens of thousands of taxparers della rs and all because of mismanagement on the part of che Cc=issi'On. You all know that properly installed nuclear power generators are safe, SII-t.s different from SII - 2, S2 -1 has been nodified a nd should be started D}EDIAc:.LY. 'Furhtermore, the unusual delays that the Comission creates in it's Burea ucratic Slow Down Process is costing America 31111ons of Wasted Dollars. Another example of over-regula ting is at Midia nd, Mich. Unwarranted Slew Downs of various approvals has cost us stockholders and the custc=ers over a 31111on Dollars, one of the best ways to Fight Inflation is to get C-over==ent out of our Pockets. 'de need rational regulation, but at the present ti=e 50 irrational Anti-7uelear Danenstr*.to: s can cost the _ublic Millions of Dollars based en nothing =cre a than Sensationalism. i Let's becc=e more realistic in our approach to Nuclear Inergy. If there is an Energy Shortage??? let$s solve the problem not ceccce a part of the Pro'olen. m d, -e ,v.,d '/ M

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l 000XIT NUM3ER PROD. & UTIL FAC.. g g 1 Janet 7. Allen i 109 Garfield Ave. Cherry Hill, New Jersey - 0800 W i k [i Mr. Gary Sanborn \\ United States Nuclear Regulatory Commission it ac esT Office of Public Affairs, Region i Qb(f g-631 Park Ave., King of Prussia, Pa. - 19406 2 T,- February 22, 1981 Y, d { Dear Mr. Sanborn s b' f, W I wish, once again, to urge the banning of all nuclear power plants. I am oppesed to restarting Unit 1 at TMI. I feel all nuclear plants should be shut down. The lesson at TMI should be enough: the" clean-up" is far from accomplished, while the seepage and venting continues. The public is fed talk of " safe levels" and " containment" to pacify anger and fear, while the truth.is obscured and the autNurie ties stall, hoping the usual lack of interest will finally set in. I, for one, cannot imagine how the NRC can continue to skirt the issue and stall, instead of firmly banning all nuclear activity until every phase of it is 100% safe from any radiation leaks to soil, water, or atmosphere - even years from now! Yhis includes at the ' plant site, during transportation, and during storage of the radioac tive - waste material. It is irresponsible to assume that any vessel could completely contain the waste for the duration of its radioactivity, s Since the storage of the radioactive waste is impossible to contain forever, even if it could be safely transported - (to what locality? Nobody wants it nearby.)- the seepage and subsequent damage to populace, creatures, water, land, air, etc. appears later. It is time now to admit the dangers and stee them. The only way to stop the danger completely and surely is to scEsp all nuclear fission plants. I suggest you include Dr. John Gofman in your public sessions, and allow his views to be included in your reports and public'ity. A pioneer in nuclear power, he is now preaching against it. Years of L studing the effects of radiation have convinced him that no level of radiation is " safe". The arguments that nuclear fission plants are necessary for economic energy must be countered with the actual dollar cost of clean-up and containment for TMI,etc. Now the public is expected to pay for it. The public cannot afford to pay for TMI,or for any future accidents there or at other nuclear plants. Each accident is ultimately reflected in increased costs to the public through rate hikes. If the utility companies had to pay for the clean-up themselves. they would soon conclude that the nuclear plants were not such a " bargain". Well, it's no bargain for the populace to have to foot the cost, either. Add-ing the monetary cost of repairs, clean-up, storage of wastes, etc. to the regular cost of the power cresents an entirely different economic picture. To this you must add the incalculable cost of future damage from seepage from waste facilities, etc.

Added to the hazards of regular operational accidents at the plant, ' I transit, and during indefinate storage, and the potential economic strain of paying for them, there is the possibility of sabotage and of-very real danger of vulnerability for tremendous disaster in the event of war. Please do not allow the pressures of the false economy of nuclear energy convince you of its safety. Listen to the real experts, like Dr. John Gofman, and to the concerned public who has no desire to suffer the " calculated risks" others are willing to take with their health. Close the nuclear plants and insist on the safest possible clean-up of the current TMI mess, as well as all nuclear plants, re. gardless of the dollar costs. We cannot afford them, healthwise or dollarwise. Sincerely, e ,.-e. e.. ~,.

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OdCKET HUM 3f.g PR03.1 tmL U.C.... _W R. D. #5 York, PA 17402 March 5, 1981 j e f r ;- l b y ~cegD Y Ivan W. Smith, Chair =an sJ es,i,^C h / Atomic Safety & Licensing Board Panel j ' c[g I 6 gg', A T[g @/ TMI-Restart Proceeding F U. S. Nuclear Regulatory Co==ission ,3 3 3.b8 Washington, D. C. 20555 D b{/,m. J In re: Docket No. 50-289 (Restart) x l 1n

Dear Sir:

Unit 1 at Three Mile Island should re=ain closed! It is ti=e to enforce the regulations pertaining to nuclear power plants. By refusing to allow TMI Unit 1 to restart, all licensees will know that they are not exe=pt from having their licenses to operate revoked. Inco=petence and =ismanage=ent is no excuse. Let that be one of the " lessons learned" by the nuclear industry. Met-Ed (GPU) did =islead the public as to the severity of the accident, anc there is no reason to believe that they would not do it again. In order to protect their investment they =ust downplay any accident, no =atter how serious. We should not be subjected to the risk of another accident by the sa=e people who brought us the disaster on March 28, 1979. We now have a severely da= aged reactor and an unantici-cated a=ount of nuclear waste in our area, along witn an TdTIEg, fully fueled reactor. During the cleanup (with an. ad=1tted possibility of a serious accident) it is not a good policy to have the fuel in Unit 1. The fuel EUST be removed from Unit 1 while it is still possible to re=ove it safely. The people living in the area surrounding TMI will be subject to unhown hazards during the long and co= plicated cleanup of Unit 2. Also, the radioactive wastes stored on TMI are an ever present threat to the health and safety of the people living nearby. The accident has been a very horrible experience for =yself and =y family, as well as for our friends and neighbors. Allowing the restart of Unit 1 will make the stress more prevalent a=ong the knowledgeable people in this area. As of this day, I have heard ncthing about a solution to the =any proble=s of the impractical evacuation plan. g0

Ivan W. Smith, Chairman March 5,1981 Page 2. Many people are saying that the Atomic Safety and Licensing Board will allow TMI Unit i to restart regardless of the problems involved. The promises of Met-Ed (GPU) mean nothing, as has been seen by their previous actions. I hope you will consider my opinion because it is backed by a great deal of study on the matter. Three Mile Island has been a financial disaster for all, and the biological effects will show up in the future. Sincerely, [.*4 e. ;.. C5 'N ~ -e Alice A. Herman oc: Dr. Walter H. Jordan ec: Dr. Linda 7. Little P O e 9 p m,. 7- -,v-. .v

s.- jQ /92l q.' ^ ~ n. ... Federal Assistance for Three MiliIsland ". l Is Backed by & clear Panel, Congressmen By Juem R. Esassiwitaa.m 1 AsWy an miluenual former Congnss-A asett Asseme af 're.m w*u. seusv Jui,em man from Otuo. to help fashion an aid pack-Efforts to secure federal help us imauc. age. GPtl also 13 soeaing 54 bt!!)on in dam-W 'ing the clean up of the damaged Three Male am s from the federal Nuclear Regulatory

• OI Oxnnussion. alleging that better govern-b, taland nuclear power plant are gaming mu.

ment supervtstun wrc have prevented the g mentum. I A presidential comnunce un miclear dCChient. The claim was !!!ed, but' the safety deuvered a letter yesterday to Pn w. agency hasn't yet nspo'ided. dent Reagu recommending daruct feletal Committee's Recommendation H sad that could total hundreds of milhons of The recommendauon by the Nuclear di dollars and a itke amount of aid in the form Safety Oversight Committee. catald be mflu-of a federal loan or loan guarantee. ential because of the parel's status as a rei-W At the same Ume. some Congreamen auvely tudependent participant in the are drafting a ball to create a quasa teueral cleanup quescon. The committee, chaared o, insurance company that would pay fur a by Art;ona Gov Brxe Babbitt. was created large part of the clean up by chargmg other by Preudent Carter as a result of the ThreJ ,P of28tles with nuclear plants a total of at Sille 1sland accident. least 1150 milnen annually in insurance pre-The call for federal aid was backed unu-mlums. Those cf.arges probanly would be imuusly by the four memcer committee. passed on to the customers of thuse uuhues. said an alde to Governor Babettt. The com-The two actions are part ut a gruwing mattee recummended that tne federal gov- -} movement to deal wnh he enormously ernment provide " direct support" for half of costly. complex and potenually dangerous the unmsured c!eanup costs at Three Wie 8 probiams posed Dy the cuotaminated reactor Island and loans or loan guarantees for the near Harnsburg, Pa. The plant haa been other half. The loans would be repaid with 3 closed smce a severe accident ut in Sub-interest by GPU customers. However, the sequent clean up efforts have moved slowly, committee's letter added that the precise I plagued by techrucal problems and escalat- ' mixture of direct aid and' loans should be i ing costs. Current estimates put the cost of secundary '*to the compeumg need to pro-the clean up at $1 bilhos. Although some uc-vide financing for an expedited cleanup.'f I servers believe the (taal pnce tag could be The committee also said CPU sttould re-much higher, teun pnmary responsabihty for managmg Spendlag by GPU the cleanup. However, high level radioacuve So fa'r, federal money hasn't been used; wastes at the site simuid "promptly" be n-General Public Ut1 Hues Corp, the plant's moved to a federal tepository, the commit-owner. has 1300 milhon in private msurance . tee added. This acuon could require addi-coverage for the plant and estimates it has tional congressional funding, the group said, spent anout half. The remalmng $150 monon The draft ball for a new insurance fund could !!nnnce operauons at a cled bacs was put together Dy Rep. A!!en Ertel. (D., levet unut the and of nest yeur, tiptl said. Ptu wnose distnet meludes Three Mlle Is-When the himurance money runn cui, it lami. He heads an ad hoc delegation of tan't clear who will pay for the diumtatuma. Pennsylvanta Congressmen who have been uon. GPU. whicn has been pusned to the looking mio ways to pay for the cleanup. } bcnh of insolvency by the accuJent, says at The propused msurance company would doesn't have the money to do it. Uuhty regu. be empowered to pay 75*. of the otherstie i g lators in Pennsylvansa and New Jersey, msured costs of cleanmg up any futue cce wnere GPU operates, contend the ratepay. dent at a nuclear plant, after the hrst IT,0 ers shouldn't bear the costs. Attempts have mdhon. The Three Mile !str.i accident e been made to conymce other uuhtaes with would be included under the s.,verage, nuclear plants to help, but so far none has To fund the insurance plan, each utility (( voiunteered. with an operatmg reactor would be com-b Pressure is tiusiding to fmd aume solu. pelled to subscribe to tt.e coverage or have 00:1. As safety equipment within the factisty l*J federal nuclear cperating !! cense re-ab detertorates. Lt.e risas of new raulauon re-vuked. An aide to Rep. Ertel said premiums leases increase. would be based on the amount of nuclear ca. Mt Thus, par'.les involved in the uusnap pacity a utility operates. The aim would be have tarned their efforts to wmntng feueral to raise a muumum of 1:50 milhon a year f!nancta! besp. Pohucal leaders m Pennsyl. nanonally. In the first several years, muca In 1 vania and New.lersey have backed the idea of tr.e premium money would :1kely go to of federal aid. GPU recency Mred Thomas cleanmg up Three Mue !sland. b)h ~~-' M shs T.in b Whk T= C'hL. . ~.. ~

I \\p)p, t '. y'- /)? W r -( M D' + i i . Letters to the Editor C C Three Mile Island: Who Gets the blil? IE The Recenuy, the Nue: ear safety Overugn Any monetary autstance to CPU from a& Committee, chaired by Artzuna Guvernur the federal government must rest on a eco! Bruce Babbitt. recommended to the Prest solid policy basts ratner than this make. $ stat dentathat the federal government tacur all shift, albeit ingenious, argument. The fed. sens financial 114tw.11ty for cleanmg the rt:ppied eral government did not dec!ce to butid the for reactor at Three Mile taland (TMit This Three Mlle Island reactar. It did not Yor call-echoed by the Pennsylvanta Puolic chume the site. the reactor or the operator. 1 I Utilities Cammission and General Putuc Rauier, the government established mme pert UUltues ICPUI-prupuses.6 raid un the mum standards that the uulity met la dea C11n' federal Treasury amnummg to approxl. velopmg TMI. Federal standards sought to bett mately $1.2 tuillun. The assertion is that etnure the safety of the general public. The vida. the goveroment should pay clean up custs legislative intent was not to establish a *, cent solely on the basis of its long atanamg as. casualty property insurance system to pro. fron soctauon with (ne nuclear industry. tect the utility from its own managertal de. cort The federal government, the arpment c:stons. Surely the utility recognt:ed as inct goes, sponsors nuclear research, promotes much when it tous out a casualty msurance job nuclear power, regulates tne atmg and de-policy of 1'100 mdlion for its reactor. esta sign of nuclear power placts. heenses their D0es there extst then a polley for fed-ovet operators and even approves and audits eral aid to GPU? One could reasonably gorb their plant procedure. Given thu pervasive argue that in meeung its responsibulues rate involvement, the Pennsylvanta uultties for public health and safety. the federat Yori commission and the uulity thma the led. government should help pay the billion 401-first eral government saould clean up the na. lar clean-up costs. GPU cannot meet these com tion's worst nuclear accident. costs an its own and, without federal he!p,

• num The state regulators and the utility aj.

the pelle safety wt!! cont:nue to be Jeopar. tion. lege tDe government is legally respmsible dued by the su![contatninated reactor. !W1 because of its promouonal and regulatory One might also argue that the government b ~d " involvement" with the mdustry-a kind of retains its interest in the development of N bill by associauon. U Uus "Involvementa nuclear power and that a clean-up at Three eme ' approach is accepted. taxpayers should Mlle Island is necessary to the future of City , prepare themselves for substalrual pay. the nuclear opuun. It is on these and other been ments to a diverse array of passable vie. relevant potats that the federal role at TM1 Yor) tims, whose only factual cla4m is that they should be argued. There is no shortage of rate had the good fortune to keep the bad com. specious arguments to divert us from (fus not pany of the federal government. critical debate, but we soon will be short of wide Despite the undeniably large guvern. both ume and panence. crea ment role in the aar transport industry, for ALLEN E. Errr.t. (D.. Pa.) incit example, no one has ever prevailed upun U.S. House of Representauves hatta the federal government to picar up the tah Washmgton utdtu for AA air!!ne crash withbut hrst provmg Mr. Ertri is chaarnuts of the Congres. D'IU ' that the accident resulted from a specific stunui ad Hoc Task force on Three.tfd, peum fadure by the government. 1 stand. n ..Ispenc, w i l i i h\\ i

.ll 7P 9ONAL BUSINESS AND FINANCIAL WEEKLY JANUARY 5,1,981 Jhina Syndrome 9 Sm.cc theThree Mile Islan i / vice to as electne customen. It accdent March 28.1979, GP1 also must ra se 5400 milhon to an-- - -n~ --

• """""~t""-""-

Only for the Owners of O' ** '"31* CI" PSl' 3"',Nnd ' "lm'== mn'"es'd ##* cunties witbn five yean. GPU d General Public Utilities im d revene. De comp. the company will not be able to 8 'e b an A*8I IDC5# CO8La 00 518 0*n- "I# E * * *

• CO
• CI'"

THE CAFETERIA of Gen. l Apee to Daapee "GPU ard its operaung up the re.ct r, a j b wbet i eral Pubbe Utthoe> Corp (GPU) is no run of the mdl, ; indeed. everyone responu. cornpanies don't bec avadable ble for the future of GPU and any source of funds to pay the -(pe[e } 1st u throme and plasuc company eatery Quite the comrary. It ts tu electne cornparnea, w hieb cost of tne clean up mthout w. p r help and ta> petiucced tr'. nandsome!)- decked out mth FNvide service to I 6 mdhon nously interfenng wnh the re- [ew Jun) and Penns#am nuscher block tabica and Breuer homes m Pcnnsyh ania and quirement of servtag the elec. bew Jersey. agrees bankrupwy inc syuem." company o(Ticials y], jf(( (( y' .tairs Emplaye, look2ng up trem five sided lunch trays itaze u noi the amwer That 13 the tesu6ed in November. "Just to b 11y je [{e ch [ a through over >aed wtadows at only tbng they agree on. provide funds oceded to assure Commission (NRC) a$ ne rural countryside abch sur. Where does sabauon be for numi service at the level of vunda their headquanen to G PU? The state regulaiors utes the system hu been expe. launched a 5750 edhcn neg.I. ' orthwestern New Jersey pomt to the federal gesern. nenemg, 5700 =dbon to $600 Tbc sinkms contrut be. ment. member > of Congess. for rmlha os capital from oes [*7dc ttheIeI' ch b

• cen the spilly dtung room their part. point to the states tovesurs wdl be needed. Every go,-

dellar of clean.up expense 2nd the holdag company's and the nuc! car indusirs and. arab future understar.da bi) wubout esception, officaldom would save to be added to Meanwhije the company thu leanmg heady on a revolvm nothers GPU Chairman Wd. thmL> the onus belon g-on G P U's fmancal repons, credit agreement mth a conse: aan. G Kuhm. for accordmg to GPU stodholders. raiepayers . Sh000 analysa of GPU > and management GPU stock, however, aren't ternbly attrac. 'rospe.ts, tue company may be bolder > ratepayer > and man. uve m mveston. Openung rev. ne "fasst m4jur uuhty'since the agement point in the federal enues before.experuca through Sept. 30.1980 were 51.36 bd-Jepression to go bankrupt." government.Each concedes it 'Tbc buddag was just about needs help from tee uher and bon compared wnh $1.10 bil. bon for the fint nine months of uum of 45 banks. The arnage ompleted when we had the ac. that soractbag must bc done iden t." Kuhns comments al. But e New Jersey Board of 1979 But net tocome was $19 I ment catends up to 5292 milbo ost spolegetxally, "We didn't Pubbc Uttbuc> Commanoner mdb o compared to 581.2 cul-in credit to GPU as a whoic e the idea of movmg mio a Edward H Hynes noter "Tbere b n the year before. And GPU wub linuu set at specific leve! buddag when it looked is Juss - macbnery m plaec carnings per average share were for the three operaung compa we mght go bust, but we now tu bnng us all together." 31 cenu for the first three quar. ten f H80, canpared m St.33. Jed the room." What GPU need.s is clear

• naes. The loans are secured, u Company offic:als said they Talk of bankruptoy for the even tf hem that need a to be have prepared revenue projec.

.part, by the uramum GPU use 'any. wtuca owns the enp-sausfied tsn't. It requires about u ns fm 1981 fu mtunal re, m zu adear nacton and ari Three Mde Island nuclear 31 bdhon to cleanup the TMI !! ed every su monds. revige company and New Je view, but dechoed to make the .or and three electnc com. nuclear reactor tn Middletown, I " pubbc.

• So much de.

8 es, his subsided. Two stud-Pa., and another $2.3 bdhon pends. on the regulatory re. the aforemenuoned through 1985 to mamtaan act-spese m our situauon," one of. eey aad Pennsylvarua uuhe ,000 Tbcofore Barry & As. I'C*I d. Commmiom are banking or tes reports and a 5500.000 The company's bonds are fecual naustance, cather ett

• conducted by the Arthur 4 Co., concluded bank.

now ratto si below investmem. Uncle Sam's cooperauen or vu y wouldn't sche GPU's grade q:a hty. GPU stock. Conunued on pog, 2c wbch was trading at $18 a .iems and could make share before the accident and gs worse. payug 51.80 annually in divi. deuds, now seus [or $$ and gas not paid a dividend for four consecuuve quarters. 9d

.~ 1 4 CHINA SYNDROME? Bus to equale GPU with dustry spvkesman, and the av a murt mandate growing out of Het in lland i Chrysler or Lockheed or any socaauon of electnc companies the neghgence suit. GPU Whde suing the govern. other non-regulated industry is known as the Edison Electnc charge > that the NRC failed t' warn the utthiy of an incider" ment. GPU is also pohtely re. to rniss the point according to lastitute have taken no posinon as the Davts Besse nuclear plant questmg federal granta Compa. Pennsylvania's Consumer Ad-on help for GPU. General Pub-in Toledo is months before th: ny oflicials. joined by staic reg. vocate Waher W. Cohen. "If a lic Utalities has suggested that TMl accident As at Three Mde ulaton, point no the heahh and DC-10 goes down, the airhae all electric companies impose hland, a velve at the Toledo safety problems posed by the can recoup the loss Wouf,h what would amount to a :- unu failed m clou, allowing v'* reactor as one factor justdymg higher rates ud you can always mills a-month surcharge on the ' tal coolmg water to bleed out of federal help Too. they argue, fly another airline," Cohea ca-average residenual customer. the reactor Unbke ai TMi, W4shmston's strong adsucacy plams " Chrysler is goin3 to pay which would generate 1100 mil-of the commercial developmens i back its loan through hig,her lion annually that could be giv. however, no damage was m' flicted on the reactor, also budt of. nuclear energy mandates fed. I pricca on its cars, but you don't ' en to the company, industry of-. by B&W, because the facabty cral mtervention They add 6: ; have to buy a Chrysler Corp. Scials are skeptical of the idea. E automobile. A isn't that way for government autstance to t was operatmg only at 7% of ca. troubled companies 13 not un. customers of Metropolitan Edi. New Jeney Energy Com-pacuy and operauons were soon resumed known. However, federal lega. son iMet Ed), and Pennsylva, massioner Joel R. Jacob >on n % hen trouble struck. TMl laton, even those represenung nia Electric Co. (Penelec) here incensed by the todustry's pod-duincts served b'y GPU cumpa. m Pennsylvarua or for custom. tion. Jacobson calls tne todus-ers of Jeney Central. They (37 8 f**ponse " cosmetic con- . have ken relucara m 6 h d was operaung at 979 of capae- ,t,i who e arms a Suppon the ples. itv and the lack of covbag water rEsuned in the plant's core over- "Ijust don't know if we can House sub-committee invesuga. cern, coupled with calculatt.J uon on the Three Mile Isle.nd indifference. It's time for them heating to the point where the conunue to aid co,mpanies that accident and its consequences, to show some statesmanslup fuel rods were badly damaged get into trouble, comment

• holds that there is no precedent The industry just can't_ expect and released radioacuve paru.

U.S. Rep Milbeent Fenwick cles. in the procca contammat-(R., N.J.), w hose dotrict con-for a grant, but adds he may be the regulatory commissions is mg the contamment buildmg. tains hundreds of thousands of able to convince has fellow leg. handle this thing alone." The islators to fund some kmd of regulaton agree, saymg that ' The NRC probed the Davis-GPU s Jersey Central Power & perual loan program. The dif-they can't ask the customers os l bene inc Jsat. bui GPU clatms Light Co. customers "They ference between what the loana JCPAL, Met EJ and Peneles to have cut then div ide nJ. re-that nenber it, nor its operateg provide and GPU needs, he aboulder much more of the fi-t I . Comparues. were informed of duced top officers salane> and feels, must come from the nu. nancial burden of the ace 2 dent me u hce the Comminion's findmgs. "If d Cleas industry and the states. g pg,3 j.6 milbon custom. 4 proper warnmg had been giv-g od ud we'ry commendable Bota Cohen and Alfred L. ers now pay $24 million eacn en by the NRC, the TMI acci-dent would have been avoid-But my mctmanon n to be very Nardelb the New Jersey depu- . month to purchase replacement ed. GPU soniend. Beddes leen f federal mienenuon ty puohc advocate who s moru-power. Stace Three Mile Island. tonng the JCP&L situanon. to-customen of the three electnc cekmg the cost of the c!can up, ; Rep. Allen L. Ertel (D.. sut that federal miervention companses have suffered, orn av-Pa ), whose datnet mcludes must take grant form. They erage. 3M jumps to their bals. TMI !!. dismines out of hand argue that loans would place a more than half of the increases the 14 bdhon clatm asks for the argument that the govern

• gieater burden on ratepayers.

stemming from the accident: damages to cover restorauon of ment bean a responsthihty 5e* who would be forced to absorb the urut to service, replacement cause of iu role tn promottng the (mancmg chuges. Funber. power. loss revenues associated nucleas energy, "With the es* they aver, smca the loans need Algry customers - sane of with the New Jeney and Penn-caption of Orville and Wilbur to be repaid, GPU's long range whom are rettrees who had sylvania decinons to remove Wright. the Uruisd Stain gov-circumstances would not be planned to use their GPU divi-the reactor from rate bases and ernment has been the strengest helped. dend checks to pay their GPU interest sumin proponent of avtauon the world company electne bills-have Kuhna strennes that the law. has ever noen," Ertel pointa out No Response flooded both commissions with sun is not frivolous, but a "Yet, each uma a DC.10 goes Cohen and Nardelli joined angry letters each ume they ap- " damn good one " Donald down you don't see the federal with Ertel in calhng for aid prove a boost. New Jersey Winston of the Atomic Indus. government rushmg m with a from the nuclear industry, but Commissioner Hyees notes that mal Forum. a lobbytna group check book." so far there has been no re.

• he has been :orced to vote for for the nuclear industry, ob-spcase. The Atomic Industnal sut increases for JCPAL smcc nerves that a successful law 6uit forum, which serves as an an.

the accident. the hike in May wdl have the same resuh as.a forestalled b4akniptcy. Hynes lederal grant "Ulumately, the instats that he tsn't trying to step money wdl come out of the out from under responsibthly wme pocket." Winston says. when he suggests the federal "It's an attempt by GPU to . government play a large role in .pread out the costa of the acci ~ GPU's future. "Who is responsible for > TMl? Ed Hynes is not." tne l dent over ths enure popula-C""Moner says. "We don't uon " l l

China ~ Syndrome? want to lay the entire burden at At Odds certainly not try ng to make the feet of the federal govern. But the interested parues money on & U people see tlus ment, but look at the record are at odds on what form the ,as a bailout,1 can relate lo that. The preamble to the Atocuc aid wdl take or when it wiU I don i think government is Energy Commasion, the fore-come. On the latter score, there there o do that. But I urge peo-runner of the NRC, >4ys in ase two key daies The first is Plc to think about what hap-Pened todent the one that wa> us. We had the mdus-purpose t> to promote nuclear when the NRC 411o4 TMI I to energy. The federal government return to wervwe TMll was out try's ace 2 Sub> dtzed at throt.gh research of servwe for regularly sch:d-tnevitahic, accordmg to the programs, hcenses at and pro-uled refuebug and mamtenance resident's commiasson which motes it u a way of reducing when the accident befell in invesugated the accident. I our dependence on foreign oil." twin. TM1 I wa not involved in don't wani people to read any. A U S. Depanment of Energy the ace 2 dent, nor was it dam-thing ominous into this, but I repon shows that the U.S. has aged. Since then, pendmg hear-don't think we have had the last shelled out over 537 billion in angs and tests, the NRC has accident. subsidies to foster the growth of kept the unit shut down. As a Kuhns believes a uulity is nuclear power over the last 30 result, the Pennsyhania and not to be confused with an un. yean. New Jency corormssiota have regulated busmess. "In the free To date. GPU customers taken TM11 out of rate base. a enterpnse system, you make a have paid not one red cent for decisaon which u bemy chal-bad umbrella, you go broke; tt's any of the TM1 clean up The lenged tn the courts of both that simple." he sayt "But it's states and a wsung GPU nul-not the same with a utihty. Reg-work is bemg funded by 5%0 bons of Jollars each month. ulatinra impose limitations on milbon in insurance (the mau. Both wmmasions haic in-nska and limitations on stock-dicated that they wdl return holden We ge: the same rate of mum available) carned by General Pubhc Utibties New TMI I to rate base as soon as return on a hght bulb as we do Jersey has yet to decide afit will the NRC shows signs of bring-on a nuclear plant. You can allow JCP&L customers to ab-tng the unit back on stream. change all the rules and have > orb any of the clean up costs. "Without TMI I back in base the shareholders bear all the Smce JCPit owns a 2M share rates soon. GPU goes under, nsk. But if you do, you bve to of TMI. its loss could run to declared New Jeney Deputy I let them enjoy all the benents-5175 milbon Pennsylvania's Pubhc Advocate Nardelb. "But . Otherwae. you won't get any-two GPU companies own the d' f *"I '#U"Ch 80*** ID **'IY ' 88 a invest a dime in a utih-remaimng 7M and that state's 1981 when the msurance mon-I ty., E Pubbe Uithty Comma > ion has ey mrn out flatly ruled out foretog custom-But even in that regard, ev-er> 4o best any of the financial crythmy an't eut and dned. burden of the clean up. Last sumnier, GPU slowed "We have said that, but we down clean up work at TMI 11. . have also said. we have no in-delaymg by two yean the carb. tenuun of lettmg Metropobtan est possible daic the uma could hdaon or Penclec 30 into bank. return to ><rwe. but stretchtng ruptcy through the result of the out de insurance money action, or lack of action, we Unlea the banks decide not take," notes Pennsylvania Pub-to renew the loans, to which hc Uuhty Commission Presi, case GPU's problems come Jent Susan M. Shanamon That quickly tu a head. Kuhns thmks view is shared by othen respon, the pivotal date for ha compa-uble for GPU's future Federal ny witi be wmeume m W51 ofTicials, who pubbcly balk at "We have to have a c!can up providing sad for GPU. con 6de funding prossam in place by ,irivately that it weuld be "to, then." K uhns states "We are ially ine>punsible" to let the not ask my los replacement .umpany go under and pledge PO * *' C"$"- os to restore the that it will not happen. dmdene we lost, that will come from our lawsuits We are

I i An.Lzu s % k mnme Ettvirousnental Aelion Fouinlasant Vol. D. No. 4, Ntncaiber 1Y811 MAR 181981 > -3 (trumcally. to grant a operating Ofka of theSet4 heen>e f or TMI 1. the sac n.ust find Of CPU tu be /nwaaulty ht, as wedJ C3 hh hn L ]a wp hn qpQ j Company wbuduries have ideJ tur a %4a %r kJ 3 I ILU Jww N 7 tot.1 ol 5317 nuthun m rate bne msrc43-C) es bef ore the New Jersey and Pennsyl-

• anng B Cleanup Bd/

vanu suninnn uns. And GPU has wrd u.ua.na wd n,. uuaar a d.c.tip Deepens Company s Fm' ancu' lCnsis s pied 1Mi 2 seauor, tur $$vo anihun m da,u,> ,u, _.,.negeJ,ae m,ue _ ascident mic ts running out fur Gener>l Pubhc Utahues A year I and a half after the acadent at Three Mdc Island, He inund recou ry w un't be ran ene nation's fourteenth 44rgest investor-owned clee-inen it (.PU can resurt TMI I and ap.n tri. auhty sonfronts a steaddy worsenmg f.nansul en>n een a erwrn un a, and even d the sum-ibe Jccuntar unanun of the Janaged iMi 2 rentur is p.n v wm> wientanud new tage increnes plagucJ *nh rechngal and puhucal uncert.moes and the gnerc, mams me sm d matter ut the bdl prac tag fe the 5 to 7 year operauun has rescady in6teneJ ius the unpung deanup at 'IMil au sa3 3 nuihun-4 figure substanually above the plant's ungu l hn nu,e h.> mos cJ tu sca tcr styr nal s onsuu6 oun eu>c. inuo.ug n. rni PUt u tnian m Penns. ) o,n in v. ...d.i a..a ny 5i;.am.~n I MI 1, the und.magcJ reactur at the site. n sh.a down m-d6 t nnidy. pend.ng. N warar Regulatury Cumnniuon dcussun m enn,,p ng gae,gg.t io sco upo.n o, i dn.,n to a 4.PD 3 buduty, abe Inor un *hether GPU is quahucJ to reopen and operats the plant. 'I he New Jersey and Pennsylvarna uuhty comnnssivns have 3.yt. 6..munun.nris restated that puu Ict t.PU'> three operating subs 4d54r es raise ratcs by hundreds tion th.a "ilemup costs and npen.h sures not. overed by mvirarne altunate-un mdhuns of Jutlars tu pay fut replacement power, but the h.re the respunutuhtv ut the t.um-annana.uns have al>u excludcJ both TMI l mJ TMI 2 from pany > maodtholders and/or the i.ednai the s ompames' rate bues. Thu reduces GPU's net earnings p,vernment, however they are not the by unne 5d5 nnihun a year. responshinty ut ratepn cri." Ihe prne of GPU stock, meanwhde, has tallen trum Sid At it.tcment retic

• ts the ionmm to $5 4 share smce the acudent, represenung a loss fut the wonen' bebet that these susts art n. +

l cump.ny's stockholden (un paper) ut $775 rndhun. j t he sumpany wdl also suun reach the lmnts of the hne ut neopa opnaung caprnn 11 aho rrikas ihr gudun 4 tens o( h h-Aa t.oinnns dnut term credit extended to it by a curtsortium ut baks. It io,n e, l.mn s la wir, had ihr pn ss has virtually no chance ut ubcammg access tu capital madets ' 8 h" Ve nn * * * **

• dn I'm al""ti 9 i m the near future.

3 " * "" '" ' k '"" P ' " D ' ' * " f l' d Y " ' GPU h.n thereture slashed its construction program, detsr-Ihrid minun belure Wa happens " r ng the planneJ Forked Ibver nucle.t preJeets (among other9 ""P"" mdetmaely It's chmmated its dividend tu stuckhuiders And """" *""'#"""'A'"#"I'***""* l ihe sumpany recentjy suffered ts first quarterly luu m "# " ' " * * * ** E " '""^**# hatos y enh mdudmg the layu(I of 700 wurb Ihe Inninn hne to this ur.re!cnting tale ut t.manu.i win is er>. $00 us them at the TMI wie. blundy suggested by a recent managernent audit womnumun-cd by the Pennsylvama PUC. "GPU is now a smdidate to be AC'""P 'ust> d dn't seem suth a the tarst major utdary to go bankrupt smee tne Depression." 6 rus ul n>ue, ut cour>c. wbtn crervune thougnt GPU's $3v0 muiion m propert y m>ur.m e un the -.e unhty, of euurse,is stryghog tu avmd that fate. It's preumg IMm would er ment W de espenw h & to reupcn l'MI l and s umr.I J da-mg the w rto.n of miervenurs m the M....d di.t mn mey are tou W NRC proscedmp ahu may CPU pven.a Now is t.PU's ratepayers are anwined past reuerJ. m not managerudy ht to uperate nudcar plant > l ~, ~, .....-m

e i POWEH 1,1Nh/NOVEMBEH 1900 Irum a hmited number of alternative a reorganiaation is probably both inum. '"*W" N *" sources. ncM bid certain/* 'I"""' 'E"""'*" One obdous plase to turn in Wohmg- "" E' '" '""' ' E" tun. PUG shair Susan Shanaman, calhng any unknowns compinaic the w atinng.dl p.artin that "all of our health, fut direct 16dcral amtante in the sican-tak of predgung what nught up, pmnn out that "m terms of hard, happen m the event of a GPU appheabic to IMl-1 must he fullv (om-coM nonomin, the 1 Mi n vident n as default. llankruptcy, after all, n a totally phed with NRt' ruguirements must dng anus to shousands utn.n th..usanda unf amihar expencnce f or today,> cles tric '"I" " " # * "W "N""#'"#"" O of Pennsyisannans a aic an uh-hekhmg u tshties.11uwever, two changs wem deart "" '" " * " T #' "IE'"'#" *" N vok ano, a hurtn anc, pawned Blund, ur a electne service would cununue tur GPU the puhin lloundermg s ompany." customsts, and there would be a lot of Ilu t (,1,t s.. ih a nin aimg Imam ial con-GPU panids nt llerman Dieskamp, in brigauon. diuon, nd the impact it. liaung on the a letter he ibc Pemaylvama congresnonal Quanulymg the impact of a bank-IM14 ilsanup pa os os, ohuously m delegauon, ha vgued that "the acadent ruptcy on rates as difficult liut a recent y,., g, y.,,, ggw g,, at 't hree Mdc Island has become a na-consultant's reputt prepared for thc New uunal Icarmng espencnce in the evolu. Jency uulity commisstun estimated that the company tu reopen TMI.l.The corn-uun ut development of nudear energy GPU's New Jersey customers might face misuun wdl make that decamn within it a slear that the enure nauon will an in6teaac of $190 til5 mdhun in rates the next several munths. hcnchi iu. ! as a result ut our ninfor-over ten years as the result of such an Meanwhile, the New Jersey and Penn-tune We I shoc that equay reymres an

event, aflvania utthty cunumumns continue to appropnate mcch.u nm for spreadmg "llankruptcy appears to offer no eco.

cunsider GPU's requests for higher rates, ttus nnpast uves ihose who will benefit nunue advantages to ratepayers and m-with decisions u nlikely before next trum the e spenens e " troduces additional risk ut' higher costs March ur Apul. iheskamp went on tu call tur Iman-uf huganon, capital, and replacement At lent une obscrsci i.lusc to the cial aantance Itum guvernment and/ur puwer," ihe report's ai.thurs argue. regulatury procen d u'o n ' t think the the nusicas mdustry. 4towever, they aduat, "It n not our company wdl make it that lung, lie says Pcunnivamai.ongremonal Jelege purpuis to shwuss inun ul equiry, pu-that withuut immedute rate hiko, fur-tion h > akra4 niahhshcJ a tak turse tential tault, and pubhc puh6y. Resolu-ther cuts m the TMl deanup process to look mio tedcral aantante for the uun ot such isson may be ne nsary tu (whnh the NRC n unhkcly to,dloM, ur dranup proint whcihet through grann, the evaluauon ul the advnalnhty uf cuts in nurnul eleetne scryice twinch the L..oi s.o I...n cuar nun s bakmpi.y" uuhty conunnuuns probably won't \\n no.in d un.h n o m b....nph n.l allow), the cumpany wdl go biuke a by the l'ennsy b una PLNs Lh.et Counsel early as pecemhet. 7 j ll J oseph Malatesta also conduJes that The ubscrser, who f or ohuous ie.nons [ I, i f bankruptcy would nut be to anyone's must gu unnamed, beheso the unhty advantage, mamly because its rnults are cunumssioners stdl don't undcutand the -YN M su unpredictable. lull scope of the pruhtem, a eval 6nced . b l,1, g p [ s Whether ur not thesc htudics accurate-by the giant game of "chn ken" they 4 ly aucu the benefits and dnadvantages seem tu be playmg wah Walungton m a P TTir i j ,,.3 8 /a ' ' \\_V l of a GPU bankruptcy may he debatabk. bad for linanaal aid. Pari ol the comnus. 0 k j'" Ilowever, it's dearly the somuusuun-siuncrs' cuniusion, he lects, may be duc / M, crs' pcxypuuns of bankruptcy's conse. to the slow mouun nature ut GPU's qucinn whn h arc important. l or the finanaal dusulution. I h. l iin..o I h i o n Inu onic h.o.d'" procni, hoih soonmuunn so m inndy "It's hke a Janusaut dvmg," he re-h u med e task huo tu cs.munc "all cuumnited to penenimg a t.PU delauh, marks. "It takes a long umc to hit the opin.ns o pu,hnr i n Humal inPoniv tu A po*ubic alicrnanvc to I ankrupuy ground." -AIJcn Meyer the huoli n. os ilo 141 in udrm " wouhl In' unne f orm os plannol reorgani. Pinum hh ms luded among lianc moa Under une scenano, GPU n ald opumn n IiPU's maamous proposal that g.ll us m'raung subudunn to usher all ratspayen of nuclear unhun cun-uu'itin, withuut sellmg them the actual tnbute to TML 2's deanup costs directly TMI unus. through their bdl> a nunon wlush has the t.PU holdmg company woulJ i found lotie lavor, evsn amung the na* then be Icst with theTMl plann, the enh uun's unhn cuccutivn from the salc-and no customcn or reve-7' ) \\ Any pioposed GPU hadout by enhcr nues. It wuuld use the enh to decontam-the icdcrat pnermncut or customers ut inate TMl 2, and then reopen or decom-other uuhun sicarh 146 n puhuval smusun the two umts. All ut uus, need. obsta61n w hu h s ouhl pnne mburmount' less to say, is very speculauve at this able. Hut ihr i ompany and its alhes wdl pum t. no doubi prm on .h a consultam to the Pennsylvama hese mansve unsertamucs plate PUC pui H. "!! t.PU n noa allowed to the NitC m an unsumlortable recover sic.mup sosa ihrough ratn, and pusinun. liollowmg the Pennsyl-it the rederal pnernment does not utf er ,2m2 pec.s acmal of emagem.y rate re-tinanctal aunt msc, then bankruptcy or

"0CKET NUMBER Pr.CC. S UTIL. FAC....W.... 4' ~ New Hampshire Clamshell j , tem,tg c/o creat Bay C1a,.she11 l .j Box 110 l f Durham, New Hampshire 03824 { '81 PAR 12 P256 i March 9, 1981 Y \\ ht \\ l N f Ty '," l L'Cf.'7'

1. [

DOCKN % l USNRC 6I MAR 18' 1981 > '2 ) Atomic Safety and Licensing Board Oh C8 Ivan W. Smith, Chairman 9 e 1 l l Nuclear Regulatory Commission l Washington, D.C. 20555 N C mt \\ l I Ret Docket No. 50-289 (Three Mile Island, Unit I RESTART) l I

Dear Sir:

Thank you for the NOTICE of a proceeding on this matter scheduled for March 5, 1981. We request this written statement be included in the record. Because we here in New Hampshire tive near two active nuclear fueled generating stations (Yankee Atomic at Rowe, Mass. and Vermont Yankee l at Vernon, Vt.) and a third facility under construction (Seabrook Station at Seabrook, N.H.), we watch the ongoing series of events at Three Mile Island with great interest. We watch the events sequential to and consequential of the accident of March 1979, l with ever increasing apprehension. We find our basic concerns for issues of health and safety are being brought into ever more r 1 clear focus as time goes on. Now, added to those concerns, l financial and jurisdictional factors are creating a chaotic monster which shows prospect of involving every participant in the Industry and maybe every federal tax payer or every electric utility ratepayer. (see enclosures) To RESTART INI Unit I befort the pressing generic problems now being experienced by General Public Utilities are resolved would be completely irresponsible. Q 9h \\0 1 0 I

NRC/ASLB Smith, Chairman Docket No. 50-289 p.2 The three gensric problems that appear to be most pressing at this juncture are: 1. HOW is the waste material from TMI Unit II going to be processed and stored? WHERE is the waste material from TMI sJnit II going to be processed and stored 7 TMI Unit II brings these questions.to the forefront, but they must be answered in terms of all nuclear fueled facilities. 2. What is to be the PROCESS of decommissioning? How are the COSTS of decommissioning going to be structured into utility rates? The experience of TMI Unit II highlights this problem, but it too must be ansvered in terms of all nuclear fueled facilities. 3 How are the FINANCIAL responsibilities casulting from the accident at TMI Unit II going to be allocated? WHO is to mak,e the decision? It must be recognized that although the accident at TMI Unit II is the most extensive and expensive accident so far, it will not be the only one. TMI Unit II can serve as a mixed blessing in that valuable lessons can be learned. Decisions about TMI Units I and II will become precedents for the Industry. It is the conviction of members of the New Hampshire Clamshell that the multiple risks of nuclear fuel outweigh the benefits. RESTART of TMI Unit I, as designed, is not justified. Please give our concerns your thoughtful attention. Thank you. New Hampshire Clamshell Prepared for New Hampshire Clamshell by Sk' [, /)'M 4-y Mary K / Me tcalf

~ ' 1 67m c c -muss 2=t ce couuzncs

1. N CO48 0s.fE0

'e93 IST SCUTM FCurtTH ST. EASTON. FA. 18Cd2 ftLS7=0NE 283.488 ..E. CODE St. March 5, 1981 E TO: Atomic Safety and Licensing Board FRCM: Easton Area Chamber of Commerce

SUBJECT:

Re-start of Three Mile Island Unit # 1 The Greater Easton Area is an integral part of the Lehigh Valley, Pennsylvania's third largest metropolitan area. We have a diverse economic base, consisting of a broad spectrum of large and small manu-facturers, commercial enterprises, and a growing number of service busi-nesses, which has allowed the area economy to overcome many problems. As the largest or,ganization of b.usiness and industry in eastern North-ampton County, the Easton Area Chamber of Commerce has long been con-cerned about the long and short range economic impacts of the accident at Three Mile Island. Having conducted what we believe to be a thorough study of the issues involved in this matter, we ask for your assistance in returning Three Mile Island Unit # 1 to service as soon as is humanly possible. We hasten to say that we do not want to have Unit # 1 started until it has been determined to be safe; any other position would be reckless. Ecwever, as is commonly known, there are at least seven other Babcock & Wilcox generating facilities, virtually identical to Unit # 1 currently in service. There have, of course, been some modifications made on these units, but the same modifications are being made on Ur.it

• 1 and it is our understanding that they can be completed in the short term.

I do not believe that safety is the primary consideratien which is delaying the restart, rather I perceive it to be the potential political ramifi-cations of the decision. If seven other units, are in operation, the safety question, at least to the parties responsible for the decision, should be academic.

1. g ss.

<:.<s uca.s.T. %%. v.v.~ia =i, -iss s. ..:. a.:

I l I The ecenemic impact that the idleness of Unit # 1 is having on our area is negative and serious. We have attached a table which accurately portrays the magnitude of the price increases which have been imposed on customers in our area since the 1979 accident. You will note that the table also indicates the relief that can be expect-ed when Unit # 1 is returned to service. The cost of electrical energy is a substantial part of the cost cf doing business. For some of our ) heavy industries it represents a very large portien of their total operating expenses. When a company experiences cost increases on the order of 43% - 86%, you must anticipate a debilitating effect on the business and upon the area economy. The impacts of the seemingly never ending price increases have been manifold. Existing jobs are trheatened, and the development of new jcbs has slowed substantially. The increases in price have hamper-ed the construction industry, already experiencing severe problems. this is evidenced by the far greater amount of construction being under-taken in areas contiguous to curs but being served by Pennsylvania Power ~ & Light. In a survey of area businesses, almost all indicated that the chances for expansion in ~our area were very much limited by the cost of electricity. Our cwn program for industrial development is at a sericus ccmpetitive disadvantage when ec= pared to those communities served by lower cost providers. It has been said that the econcaic factors should not receive primary consideration in these. deliberations. The economic factors are people facters, they are emotional factors. I submit that une:n-ployment and less spendable income are severe problems which affect people. Further, it is not only business which is experiencing. distress with. regard to ever rising costs. Local governments, schools, hospitals, ucunty and state facilities are all experiencing these higher, costs. Who pays the increases? The people pay. The people pay at heme, and they pay in their taxes, and they may pay through the loss of jobs. It is the people who always pay. It is very exasperating to read a commentary indicating that the econcmic impact of Three Mile Island has not been significant because the Metropolitan Edisen rates are not the highest in the Commonwealth, not the highest in the surrounding states. That type of reasoning simply does not address the realities of the market place. Every business, in-deed every individual, plans the financial future upon a number of fac-ters, factors which we believe are relatively stable or at the least predictable. A ccmpany prices a product based upon anticipated costs. When any cne of these costs, be it energy, labor, materials, or interest rises sharply and unecntrollably, the financial plan is in crisis. Much of the same can be said fer the budgets of our residential censumers. Our businesses, therefore our people, are at a ecmpetitive disadvantage because their cc=petiters, = cst all cf which exist cutside cf the regien and state, have not received similar increases. in their ecst of electrical pcwer. l

+.4 sm-a n.~hme-

• J-2.-A a.--

-4,+4-+.-

• 6.-a-J*d.-

.-nw - + e A .Ln.$L +2_4 .__4_s 4J h We believe that it.is absolutely essential to bring TMI Unit # 1 back into service as soon as possible. Immediate relief is required, and the 8% - 9% decrease in price that Unit # 1 would provide is of great importance. Insofar as it has been determined by the Nuclear Regulatory cercanission that. the Babcock & Wilcox design is safe, we see no reasen for further delay. 9 9 l r 9 e i 4 ( t [ A r P 1 5 l - -.. _ _. _, - -.. ~., -.. - _, _,.,., _. _.. -, ~, _. _,. -, _... - _,.. _,.., _, _ -.,, _., _ _. _.. -. _ _. = _ _ _ _. _,,-.-. -_,.. m.

~ i I Cost Increases to Metropolitan Edison customers: Estimate Rates with TMI 1 Average Rates back in service i Jan. 1979 Jan. 1981 % Increase Rate- % Decrease Residential without water heat (500 kwh) $25.79/mo. $34.84/mo. 35% 32.21 7.6% Residential with water heat (750 kwh) $31.80/mo. $46.30Ano. 46% 42.25 8.8% Small commercial 4.420/kwh 6.33C/kwh 43% 5.80 8.4% Large Commercial 3.750/kwh 5.74c/kwh 53% 5.19 9.6% Industrial 2.47'c/kwh 4.59c/kwh 86% 4.02 12.4% I

e l I bM 8tm c:-mursa:n ce ecev::v_z = c2 ...... =........ _....... . se : 9 4 19 4 f.7 -43 1 IS7 SCUTH FCURTM ST. EASTCN. Pa. tsc43 gklM j g f t.s h oas s 293. 411

• • .a C004 ti.

\\ .I March 5, 1981 pf ~~ctma L:MO 3 MAR j g ggg A C Mr. Ivan Smith '31 Atomic Safety & Licensing Scard (,' 0/r:3g g <b"aya e,h7 25 North Court Street 5 Harrisburg, Pa. 17101 -Og y

Dear Mr. Smith:

b Due to the severe snow storm which struck cur State en March 5th, I was une.ble to attend the public hearing concern-ing the restart of TMI Unit # 1. I am enclosing a copy of the testimony which I was prepared to present that evening and hope that it may be of seme use to you in your delibera-tiens. At the moment we are planning to have representatives at the March lith meeting and may present cur testi=cny publicly at that ti=e. If there is any change in your anticipated schedule for March 11, please contact this office. Very truly yours, Ii ~, - J. Michael Dewd Executive Vice President JMD/sle Enclosure psA s >/0 .poe-Ti ,. e. .C., s wraars-ar*~sv>.,4 s: a

'v

~58 ' * ; 8 +;*: <w- = w r- ,e. y

s Arthur R Burkland 31130 S Gen. Kearney Ed Sp 19 Temecula Ca 9k390 Mar ch 8 198 1 The Honorable Joseph M Eendrie j U S Nuclear Regulatory Commission 1 'asshincton D. C. 20555

Dear Cc=missioner Hendria:

Every Utility

o. which has had, or may have in the future di aasters ( such as TEREE MILE ISIAND) mus t be encouraged and helped in every legal way to get back to producing energy.

j Instead they are all being hindered and unjus.,:',7 penalized at every turn - treated as uncaring and careless criminals. While the noisy, radical groups with their highly organized and well planned opposi tion are treated as hercs by the media. INE;;.UITIES CAUSED BY LEVELIZED RATE MAXINg MUST EE CCERICTED. Utilities are net allowed to make enough profits to build up reserves to he t.p cover disasters. Rate lds between' requests and regulatory decisions are unreasonably long. ?iE EEED LEGISLATICN AND REGULATORY DECISIONS FCR TEE RECPENING OF TMI-l AND OTHER PLANTS ACRCSS 7.E COUNTRY. We also need to expedite the cleanup of TMI-2. Ple a s e put the country's, the users' the werkers ' and the stockholders' needs ahead of the clamors of the radicals. respectful)y g,w., c'. O.m.'Sv. l ~ en ~ fM _a____ _ _. -. _ _ _ _. _ _ _ _ _ _ _. _ _ _ _ _ _. _ _ _ _ _ _ _ _ _. ~ _ _ _ _. _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

\\g'.\\ \\ h N /\\ DOCXIT NUM3E3 .k gCEcc q, _25._0D,.17m. " 4 (,. USW,,,~ I MAR 161981 > T-2025 Miller :.ane O h w.,.!.se tecsuti Sa::1sburg, PA 17110' Q

• Q.1 %W3 March 7, 1981

?? 9 s, /I 1I\\C i o van Smith, Chairman A cmic Safety G Licensinc Scard: TM: Uni: 1 Restar: 1 U.S. Nucles: Regula: cry Ccmmission Washing:cn, D.C. 20555 Des: Chai.~an S=1th: We : hank the Scard members !c: scheduling a special evening session on Thursday, March Sch, c a!!c:d scuchcent:a1 Pennsylvania :esidents whose daily wc:k-hours preclude a::ending the dayti=e hearings cn ~Mi-1 Resear to present their ccncerns to you in perscn. As you have seen, interes: and respcnse was high - p:cbably x: esc than ycu estica:ed when scheduling only one evening !c: :es:Lxny.

n the ~"~=*-hour period allotteda !! each speaker was kep: := a maximum five-minute presentation -- a limi:a:1cn cha: has neve: heen successfully en! :ced in cas: AS:.3 hearings -- then an absolu:e =axi~m c! cnly 34 wi:nesses cculd have appeared (allcving !c: cne 10-minu:e recess). :n fac:, the==ber who acpeared was considerably less; and many mcre -- we were n=be: F2 cn the lis: :c add:ess ycu -- remained :o be heard.

~ is :::ucial !c: you: 5 card's fulles: unders:anding and wises:

decisicn :egarding :estart of TM:-1 cha: :hese ci:1: ens he given :hei: , heir concerns - pic c: con :egarding Uni ~ 1 -- face-

1gh: cc presen:

t tc-face before the Boa:d, fc: appreciaticn of the intensi:y of :esidents' concerns abcut TMi-1 Resta:: cannot be adequately :alsed act sensed thicugh the ewtionless nature of w:L: en state =ents. There!cre L is imperative within the charge given this Scard that ancther evening oppc:: unity !c: public testi x ny on an intimate and personal basis he scheduled socn, allcwing the many in:erested and con-cerned !=dividuals who could no: address ycu cn March Sch :c do so. i We lock !c:vard :c your immediate and favora2:le attention :2 this

equest, and c sharing perscnal :evela:Lcns abou *M: as. they directly pertain to c:eration and public safety a: Uni: 1.

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RemaL=ing M s: sincerely ycurs, 6'<AnwG. lar:y -nc1d i cc: Rep. 3:uce Smith j Pep. :e!!:ey Picccia U.S. Rep. Allen ::e1 Sen. Gec:ge Gekas \\ 9 U.S. Sen. schn Hein: ::: .S. Sen. A:len Spec:e: Gov. Richard Thc:nburgh .w. ww e - i.e w..

/ DOCKET NUMBER gg} - gscoJy?' fee Gladys L Eurkland ~ 31130 S Gen. Ke arney Ed 3p 19 Teme eula Ca 92390 Mar 8 1991 The Honorable Jameph M Eendrie U S-Nuclear Regulatory Commission Washington D. C. 20SSS

Dear Commissioner Eendrie:

For the sake of the country's future,-WE MUST HAVE LEGISLATION AND UTILITY CCMMISSION REGULATORY DECISIONS TO iROTECT THE UTILITIES - WHICE APS THE VERY LIFE BLCOD CF OLR NATION - FROM THE PREVAILING UNFAIRNESS OF THEIR TREATMENT AND IGNURAliCE OF THEIR NEEDS. Plants which have suffered disasters, or may in the future, must be encouraged and helped in every way to get back to producing much needed energy. Instead, it seems to me, they are not recaiving RAPID, FAIR CE ADEQUATE trestment - while the hizhly organized, noisy radicals groups with their well planned publicity are treated as heros by the =edia and they are e xertinz . undo pressure on regulatory agenc ie s. You are our only hope. He ar our pla as. t UTILITIES ARE NOT ALLCWED ENCUGH FROFITS TO BUILD UP RESERVES TO CCVER DISASTERS. RATE LAGS BETWEEN REQUESTS AND REGULATCRY RESPONSES ARE UhnEASONARLY LONG. PLEASE EELF GET TMI-l SACK ON STREAM AND IMPLEMENT THE CLEAN UP AT TIM-2 as well as any other plants which have had or may have such disasters. Respectfully, / Q. X W./,T / "R .d t f % M(G;t.' [ i y W isu tj$NPC } [ MAR 161981 > r 3 -g ofIksett% ! mtn, m/

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s STANDARD STEEL SUANHAM. PA 17009 (717) 248 4911 +* w M!T g ut Jonn E.Fogarty March 10, 1981 s presieent DW l usN9c j". Mr. Joseph M. Hendrie, Chairman 4 Nuclear Regulatory Coc=Lission MAR 161981 > C' Washington, D.C. 20555 ~,~,, g Office of the !serstory Docanting & Savice N

Dear Mr. Hendrie:

y c 9 C Every =enth the Pennsylvania Electric Company charges their customers an extra S2.5 million to replace power not available from its " undamaged" TMI Unic #1. Why does the Nuclear-Regulatory-Co= mission not permit TMI 11 to be operated when Penelec claims that TM1 11 conforms to all Regulatory Standards. As one of Penelec's largest customers, we must be vitally concerned about the availability of ce=cetitivelv priced eower with which to conduct our business. In addition, because all Penelee pcwer is derived from coal-fired l generating stations, we are concerned about repcres that some of these l units will soon be taken out-of-service for major maintenance. It is i likely, therefore, that even = ore expensive " purchased-power" will be required. I i Itisunfortunate,indeed,thatdeliberationswithregardtoTMIhl have dragged on painfully slow. We can only urge that the investigative processes be expedited. We also urge that the astronomical costs associated with TMI 12 be shared by the Federal Government whose NRC agency was substantially involved in the establish =ent and/or approval of TMI #2's standard-operating-procedures. j ~ i Very truly yours, l 0 V $hy i 4AN73 47 SLA**4?A ANO ;,a-cCgg sa 1

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s# DOCKET 't"" U Q ) L Ql}.fhC; f A b = March 9,1981 James Ahearne, CPh U.S. MitC-1717 H. St., W Washingten, D.C. 20555 Dear Mr. Ahearne I have heard recently that the cpening of ""~~-1 is being considered. For many reascns I wish to make it kncwn that I am very much cpposed to this reopening nor de I wish to see it cperating at 5%. Without T the NM system is able to supply at least h5% more electrietty than all its custe=ers have ever demanded during the winter and last summer it was able to supply 29% more than its custcmers ever demanded. I hope you will agree that frem the public's point of niew this wculd be a feelish =cve. Sincerely, V.1//W$KL. CukL Marlene Sciole-Fox hil Jamisen, Pa. l!929 9 \\1k N

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o J -~. ) PIL\\TED COPUESPONDENC3 PROD & ~1 FAC. [. PUBUC INTEREST TAW CENTER OF PHEADELPHM ' CERTIFICATE OF SERVICE " Testimony of Bruce Molholt, Ph.D., in support of 'off-site contentions-of the Environmental Coalition on Nuclear Powern l I hereby certify that copies of this testimony have been deposited this date 16 March 1981 in U.S. first class mail addressed to all parties in the NRC Atomic Safety and Licensing Board Hearings on the . restart of TMI nuclear station, unit ' 1. 'p(/](flWkF Bruce Melholt, Ph.D. r i Distribution: Chairman Ivan Smith Administrative Judge Linda Little mailed together Administrative Judge Wa. iter Jordan Robert E. Zahle r, - Es q. __~ Robert Adler, Esq. Joseph Gray, Esq. Secretary of the NRC Docketing. and Service Branch Judith Johnsrud, Ph.D., 8 extra copies - for intervenors Y \\ // OCCKETED usNEO ~ ci: MAR 2 51981 > d (~ office er ee se en s. c: ace a smice s e.... 4 \\ 0 ~.....- _.... _.. _. _,.., -. _... _,. - - _ _ - _. -.. _. _ ~ _ _.,

l, COCHET !!Uf,*;;a fR00. L UTIL FAC. TESTIMONY OF BRUCE MOLHOLT, Ph.D. .7 ,r-IN SUPPORT OF OFF-SITE CONTENTIONS OF THE ENVIRCNMENTAL COALITION ON NUCLEAR POWER e EP (ICNP 2 - 8)' e EP - 10 (ECNP '2 - 28) e EP - 11 (ECNP 2 - 33) U.S. NUCLEAR REOULATORY COMMISSION TMI-1 RESTART HEARINGS (Docket 50 -289) Atomic Safety and Licensing Board ^ f; 9.I 4 HARRISBURO, PENNSYLVANIA ./g -: r.Tr-gea s !S 2 MAR 2 5198 ~ subtr.itted 16 March 1981 c;t,:, c; e, ge:.g7 C:::.th: L L;::::e g' (* 8:mh D yn\\ t -4 Bruce Molholt, Ph.D. Science Directer { Environmental Cancer Prevention Center Public Interest Law Center of Philadelphia i 1315 Walnut - Suite 1600 i l. Philadelphia, Pennsylvania 19107 (215) 735 - 7200 t

b Introduction This testimony is written in support of three conte :tions of the Environmental Coalition on Nuc19ar Power (ECNP). Although I have attempted to secord ea'ch conten: ion with the most relevant testimony,. in that the topics are related, there is some overlap. Hence, the testimonies should be taken as a whole and not limited to a single contention. To help in this integration, an outline follows. 4-OUTLINE CE.MOLHOLT TESTIMONY Pare EP '? IECNP 2-8) EPA Protective Action Guidelines 1

1. Tetal thyroid and iodine-131 2

2. NRC underestimation of radionuclide 2

exposure

3. Taise public security 3

Cumulative Nature of Radiation-Induced Damage 4

1. Synergy of sequential radiation exposures in carcinogenic initiation 4

2. Synergy of sequential radiation exposures in the inductica of birth defects 7

3. A summary of rt.dionuc!!de releases at Three Mile Island Past and future 9

4. Conclusion 10 EP-10 f ECNP 2 -28) 11 j

EP-11 (ECNP 2 33)

1. Special sensitivity of the fetus to iodine-131 12 2.

a. Neonatal hypothyroidisrn and TMI-2 13 i

b. Animal studies 14

c. Calculations of iodine-131 released l

at TMI-2 14 1 i 1

2. Deficiencies in the BRP Plan 15

3. Evidence that normal nuclear stations release considerable iodine-131 16 1

4. Co.oclusions 17

!.8 Refer ences 19 Tigures 23 Table s

1 Molholt EP IECNP 2 8) The fractions of EPA PACS listed on p. 4-1 of the Plan, with their associated action levels, do not take into account the total accumulated dose and dose commitment. As a r e s ult, the total exposures may exceed by large margins de Usted PAC fractions prior to the advance-ment to a higher emergency category. The CPU Nuclear Corp. Emergency Plan for Taree Mile Island Nuclear Station Unit 1 on p. 4-1 lists the fonowing fractions of Protective Action Guideline dose levels as defined by the Environmental Protection Agency: yraction of PAC Ale rt . 01. Site Emergency .05 General Emergency .1 with the PACS referring to I rem whole body dose er 5 rem child tyroid dose accumulation whereas the CPU Emergency Plan refers to fractions of PACS accumulated per heure The Emergency Plan gees on further to state (p. 4-6): The projected values for dose and dose com-mitment given as emergency action levels for even the highest class of emergency (i.e. General Emergency) are censiderably lower than de EPA PAC's discus sed above. There-fere, de declaration of a Ceneral Emergency, although an extremely significant e ve nt in its own right, should not be censtrued to mean dat de EPA PAC's have, or even wiu, be exceeded. The CPU Emergency Plan thus attempts to lun de public j into a false sense of security, that they are being protected above and beyond those radiation protection guidelines set by the IPA. In fact, the tru6 is the opposite. The CPU l Emergency Plan misinterprets the sense of the EPA PAGs and bases its " extra measure of public protection" upon this distorted interpretation. F urthe rmor e, in failing to put any potential releases of radionuclides to the public residing near Taree Mue Island into de context of the accident at TMI-2, the CPU Emergency Plan overlooks the cumulative nature of radiation-induced care!negenic and mutagenic damage to the _ public. I shall address these two issues separately below. EPA Protective Action Guidelines The EPA PACS for the plume exposure pathway are expressed as a range of 1 to 5 rem whole body dose and 5 to 25 rem thyroid dose to individuals in the population. These PACS ignore any exposures by the ingestion exposure pathway, which have no parauel in 10 CTR 100 guidelines (the PACS are more conservative regarding human health effects than

f. Molho12 - 2 comparable 10 CTR 100 guidelines). Depending upon the nature of a given accident, -the ingestion pathway may far outweigh the plume pathway in providing the nearby population with radio-logic insult. In addition to censidering the population pre-disposition to radiologic damage (next section), I wiu discuss here two oversights in the PAC approacht

1) The 5 rem thyroid dose for children cices not consider the exquisite sensitivity of the fetal thyroid to iodine-131 insult.

2) Exposures far and above these calculated by the NRC may result from even normany operating nuclear stations.

In addition I wiu discuss as a dird point the attitude of the C P U Emergency Plan that " declaration of a General Emergency... should not be construed to mean that de EPA PAC's... wiu be exceeded."

1) Tetal thnoid sensitivity to lodine-131 The human fetus develops from one single fertinzed cell at conception, de zygote, to over one triluon cells in merely nine months. The rapid division of au fetal tissue cells renders this stage of human development the most sen-sitive to au forms of genetic damage. Only de fetus is sensitive to teratogenic effects of radiation or chemicals.

The fetus is likewise more sensitive than any cier stage of human development to carcinogenic or mutagenic insults by radiation or chemicals. Hence, the lower range of PAC guide 1 Lees for i rem whole body dose win be achieved much more quickly by the fetus than by another other develop-mental stage of man. As suming that in general de fetus is ten times as sensitive any stage of childhood develop-ment postpartum, de General Emergency provision of the CPU Emergency Plan at 0.1 de EPA PACS as defined would be equivalent to 100 percent of the PAC whole body dose for the fetus. I The situation is even worse for fetal thyroid sensi-tivity to iodine-131. The developing fetus, depending upon the stage cf gestation, may be 40 times as sensitive to I-131 as any of the childhood stages of dyroid development. Hence, in actuality, the General Emergency 0.1 PAC dose for child-hood thyroids may be four times de PAC dose for the fetal i thyroid. These considerations win be expanded in the third j part of my testimony relevant to off-site contention EP-11 (ECNP 2-3 3). 1

2) NRCs underestimation of radioneelide ecosures Contemporary transfer factors for reactor-to-air and water, air-and water-to-soil, soil-to-plants, plants-to-animals j

and man, and animals-to-man have been vast underestimates due to the utilization of minimal transfer factors at each stage l of the analysis. An objective reassessment of transfer factor 4 i l e l l _, _ ~ _

j i Melhol2 - 3 values in the werld's scienti.fic literature by the Institute for Energy and de Envir onment.. Heidelberg, W. Germany, has shewn that a wide range of transfer factors exists, such dat the accepted minimal NRC values are focr-to-five orders of magnitude smaller than se possible maximum transfer cf radionuclides frem nuclear station to man. Using maximal transfer factors frem the world's scientific literature, de Heidelberg Group predicted that an individual residing widin two miles of a nuclear station, or censuming vegetatica grown entirely within a tno mile radius cf de statien could receive up to 720 mrem per year radiation exposure frem dis single source (about six times background frc= all c6er sources). The same enhancement of transfer facters applies to radionuclides released from nuclear stations during emer-g encie s, and, therefore, under de proper conditions, mrem doses as mentioned in the EPA PACS may be achieved orders of magnitude =cre easily than indicated in de CPU Emergency Plan. Since the intent cf de EPA Prctective Actics Guide-lines is to protect the public frem undue radienuelide expo-sure, any underestimatics of crem equivalents from a given event acts contrary to these PACS. It is likely frem 6e two above-menticned arguments sat, censidering se most ra dia tion-s e n s itiv e stage cf human existence, actual hr. man FACs will be exceeded by crders of magnitude under con-ditions where extant predicticas indicate caly fracticas of PAC dos e ecmmitments.

3) Tals e,Jublic s e cur i-v i. fractienal PAC e nerrency ria n The CPU Emergency Plan deludes the public into the as s umption that semehow dey will be protected by de details cf this Plan frcm expcaures to radiation deses in excess ci de EPA Prctective Action Cuidelines. This is patent nonsense. E stablishment of General Emergency as 0.1 the EPA PACS in no way assures the public that the j

PACS (at de 100 percent level) will nct be exceeded by i any given ernergency event. i It appears that dis aspect of d e Emergency Plan i was derived solely to palliate public fears of harmful ex-posure to ionizing radiation emanating from potential acci-dents at the TMI nuclear plant unit 1. Prc= the con-sideration of fractional PAC doses to de public, the r e would be no conceivable emergency which would commit the public to that carrow band of radiccuelide exposure yielding dose equivalents between 5 and to percent of the IPA guidelines. Any rapidly e scalating event, such as de accident at TMI-2, would pass from " Site Emer-gency" to " General Emergency" categories so quickly as to render de former category meaningless. In summary, the CPU Imergency Plan emergency categories are based upon archaic dose equivalent a s ses sments of radio-nuclide transfers from nuclear station to man, ignore the most radiosensitive phase of human development and are impractical for implementation during aLny actual emergency at TMI-1.

e Molho12 - 4 Cumulative Nature of Radiation-Induced Carcinogente and Muta g e nic Dama g e r In EP-7 the ECNP fur +1er contends that the CPU Emergency Plan "do(es) not take into accouct the tctal accumulated dose and dose commitment" received by citizens residing near Three Mile Island. The clock for. the exposed pubile can never be set back to zero. As a result of the accidect at TMI-2 a March-April 1979, venting of the containment building atmesphere in June-July 1980 and imminent potential exposure to tritium and strontium-89 /90 during the proposed dumping of EPICCR II processed auxiliary building water into the Susque-hanna River, the population residing near Three Mile Island is predisposed to further carcinogenic and mutagenic radio-logic insult. There is.no way that this exposed public can be considered " normal." Hence, the EPA PACS do not apply to the population residing near Three Mile Island who have already been exposed to fractiocal PAC radiation dose equi-valents. Radiation-Leduced genetic events are cumulative, that is, once introduced into the gene pool of mankind, they can never be excised. If these genetic events occur in somatic cells, they may lead to cancer. If they occur in germline c ells, they may result in birth defects in subsequent genera-tions. In bcth cases genetic events occurring at a given time are synergistic with ' genetic events occurring at some sub-sequent time, ne synergy of sequential radiation-induced genetic events in the induction of cancers and birth defects are considered separately below.

1) Svnerrv ef secuential rsdiatien excesures in carcincee.le initiation Radiation deses emanating frem the TMI-1 nuclear statien will impact a population which has been exposed on at least two previous occasions to large radionuclide re-leases from TMI-2 during the past two years:

a) 20 million curies (NRC) or 45 millim curies (Takeshi) of mcstly noble gases containing 14 curies l Two vears lodtne-131 (NRC), 26 curies 1-131 (EPA), 2100 curies' l are I-131 (Takeshi, based on noble / lodine rativ i 20 Apr 1979) or 64,000 curies 1 131 (Takeshi, bassu on { noble / iodine ratio of NUREC 0600). l One vear b) 43,000 curies of krypton 85 (NRC) containing ago mC1 levels of strontium 89 /90 (Pisello). i Field vole populations captured during each of these episodes of radiocucIlde releases from TMI-2 confirm uptake of these elements by mammals residing nearby. Maximal thyroid doses from iodine-131 in field voles was 420 mrem, which already is.084 the EPA PAC level for this one Lso-tope during the Laitial exposure. Since captured votes were adults, the I-131 levels would be higher in infant voies and much higher in fetal voles. The significance of these findings to TMI-1 Emergency Plans is that h human population my have already been extosed g radiation levels indicative g a, ] 1

'2 Molholt - 5 General Emergency due to emissions from TM1-2 in the geograpnic area proximate to Three' Mile Island. Concern-ing pubile health, the population residing near TMI does not start out with "O percent" of a PAC dose. They have ac-cumulated fractional PAG dose equivalents during at least two exposures in addition to their normal background radia-tion exposure. It is foolish to consider restart of the TMI-1 nuclear reactor as if it were in a vacuum. i A triumph of medical science during the past two decades has been to understand the molecular genetic basis of carcinogenesis. Cancers are initiated by two separate genetic events which may be separated by years (Figure 1). One of these genetic events may be inherited from a parent, providing for the genetic predisposition to certain human can-t eers, which sometimes; are accompanied by cytogenetic ab-norma 11 tie s. These special cases in which cancer predis-position is marked by chrcmosomal deletions have anowed the assignment of certain human cancer genes to particular chremosome bands (.e_.g., retinoblastema to 13ql4 and Wilms' tumor to 11p21). In the normal pcpulation not geneticany predisposed to cancer both first and second genetic events must be in-duced in the same population of cells in order to form a cancer stem ceu capable of uncontrened replication lato that clone of cens we call " cancer." Radionuclides are potent carcinogens in that significant numbers of atoms may be lodged for long periods of time in a given organ, anow-ing both first and second genetic events to arise from the same ' carcinogenic insult. Radienuclides which emit alpha or beta particles are especially insidious carcinogens. Although these particles have very little penetrating power outside the body, once t trapped inside the body, in juxtaposition to human ceus, they wreak havoc in that each disintegrstion results in the deposition of hundreds of Ion pairs per mm of track length. This density j of ionization is a major consideration in calculating radio-biologic effectiveness (RBE) of radiations, a factor used in l converting radiation exposure levels to rem-equivalents in man. The track length of the krypton-85 beta particle, for example, I is shown in Figure 2 superimposed upon a micrograph of f human breast tissue. It is clear that lipophille krypton-85 atoms stored in human breast fat can intercept target breast ductal or lobular epithelial cens with emitted beta particles during radioactive decay. Created ion pairs may be either inorganic or organic ions caued free radicals. Free radicals may diffuse from I the ton track, affix themselves covalently to bases comprising the genetic code of DNA (forming a so-called DNA adduct) and cause a mutational event during either replication or DNA r epair. Individuals homozygous for certain DNA repair or chromosomal maintenance syndromes, such as xeroderma pigmentosum, ataxia telu6 ectasia, Fanconi's anemia a nd t Bloom's syndrome, are at an increased risk when exposed to radiation to develop various cancers. Worse, it has been estimated that up to 15 percent of all cancers are found in individuals heterozygous for these conditions. R R m

f Molho12 - 6 C ce a cell dat ccetains a precarcinogenic lesien is its chromosomes replicates, dat lesion is permanently entrapped; dere !s no further possibility for repair. ""he permanect legacy left by radiation exposure are such DNA mutations in this ceu and dat throughout the body. If such cells interact wid furder carcinogenic insults, e!*er radia-tive or chemical in nature, and de perquisite second genetic event is Leduced, this ceu will beceme a cancer unless caught by the immusclegical defense system. In addition to $e two required genetic events for ! i+iatien cf carcinogenesis, a dUferentiatics step seems to be required for de genetically predisposed cell to beceme a frank malignant precursor. l'his dUferentiation event can be s pontane ous, but is vastly enhanced, thereby " pro-meting" carcinogenesis if acccmpanied by hermones which stimulate cenular dUferentiation or by trauma which injures tissue nec essitating tis sue regeneration. Many of 6e car cico-genic premotors which fail ic short-tem test systems to be mutagenic fan into this category, includlag diedylstilbestrol (DES), bencene, asbestos and tumor viruses. Radiation it-self, in that it kills cens, can also promete carcinogenesis. Cne mieregram of plutocium-230 entrapped is de alveelar epidelium of the lungs is a ecmplete car cinog e n: 1 itiating the first genetic event and, withis a shcrt period, the secend genetic event in the same local ceu population, and, finany, pr eviding sufficient locanced tissue necresis to premete tumer dUf erentiatien and preliferatics. Each Cf de abCve events Centributes tC de likelia hood of de next is a mere ia a:iditive manner. First, seccad genetic everts at:i p emetics are synergistic phenc-mesa. The first genetic eveet causes hfpertrephy cf af-fected ceus, such as ie hemihypertrephy cf &e renal cer ex seen is children predisposed to Wilms' tumer. Hence de chance cf a secced genetic event occurring widin eis c1cce cf cens is exacerbated by the sheer zu=ber of the se cens. First and second genetic events are also syner-gisticany related in that they win occur with higher frequency in dose individe tis hemo or heterccygous for the DNA repair l or chremesemal maister.acce deficiencies mentioned above. Finany, the interactics between initiating and promoting car-cinegens is synergistic, their ec=bined effect being much more das de additive sum of their !=dividual effects. The above considerations pertain to steps in car-einegenesis which initiate fermation ci a precursor leston termed "carcinema in situ" (Figure 1). There is addi-tional proof that low level repetitive doses of radiation are mors affective in inducing these lesions rather dan higher level single radiation doses from both epidemiologic and experimental studies. By no means do all carcinemas in situ become frank =alignancie s. Until these lesions break through their basement membraces and invade adjacent tissue (invasive careisoma) they are not considered cancers. This leaves

3, Mc1hclt -7 t cae last itse of host defense, the cendar '-c.ity syste=, to reject dese ca:cers before Gey can farder differentiate towards invasive es s. The rcle of the cenalar !==2 ity system is cancer -rejectica is amply attested to by de 10-100 fold e:hanced frequency ci spontaneous cancers a=c g transpla:t reeipients who have undergcce i==ceosuppressIve proph ylaxis. This censlar '-- -i y syste=, mediated by t sy=ocytes, recognizes and rejects bcdding t==or cens by their altered antigenic surfaces. 1 general is crder to overgrow surreceding tissues, ceoplastic. lesiens must dis. - i play an altered ccte r = embrace, since dese ceu-cen ece-tacts mediate cor=al cessation of grews. nis cenciar i==crity system is highly sensitive to. various i==c c-l reactive cefacters,. such as streteni and hista.= ires (pro-duced under stress) and varicus lymphekkes 1:cicding hterferces. t nis it a1 i-cre barrier to de ind etica cf frack cancers is doubly sensitive to radiatics isselts. High levels ci radiatics can ec=prc=ise de i===:e sys-tem resciti g L de e:hanced predispositics to cancers as =enticced 'abeve for !==c=esuppressed transpla re-l cipie:ts. ne cellalar i-crity syste= !s, is additics, 'l ~ sensitae to stres s, such as the relevant stress i:duced i' is the populatics residing near TLC at the time of de DC.Z accident, at a remarkably high level de fcHewing Jacca.y (Mocatal: West Study of de NEC) and still pes elder intestic a1 or naistentic:a1 releases of radiccacudes frc= de DC-2 facillef. nis stress factor is clearly ::: over and will hang over de head of TLC. area reside:ts for. de daratics cf de 311-2 clea::p cperation, e spe cia 11*/ five-to-seven years Irc= new d ring Se placced decc=a=irattes - and removal cf the DC-2 reacter cere. h sn-ary, carcinegenesis is a = ltistage process in which costrib: ting 1:scits to each stage != de evciatics l ci a cancer are sysergistic rather das additive 1: seir 9, overan effect. The stages 1:c12de: i f ) l a) T!:st genetic event "} Jceder centrol of j b) Secced genetic event) DNA repair syste=s) l c) Prc=ction/ differentiation i d) Caretem is sita (under fem.se co: trol) e) hvasive carcirc=a (= " cancer") 1 ~ Insults due to radiat!c exposure may play a role is each step of dis process resciting 1: cancer productics. l 1' i

2) Svcerry of secuential racilaties eroescres i

i != de ledcetion of binh defec*s I if ger=11:e tissues rather than sc=atic ceus are schject to radiation-induced ins cits, future g+:erations may 3 suffer birth defects. ne ger, etic lesices Larcived are those =esticced above 1: my discussies ci first and second genetic ) events required for de Leitiatics of carcisegesests. Radiation-induced liberatics cf ice pairs and free radicals will imeract I t i i k +,.,--,.....e ~ m., er. s y e- ,--. ~ 9,,,m ..m,,...,-m-,. --en ,,.w-- ~w., ,,n ,w, _,. ,we- ,-,w,- ,w., +,--en,.

I. Molholt - 8 with and mutate DNA of spermatogenic or oogenic human tissues in a manner identical with the interactions with DNA of somatic cells mentioned above. There are two discreet periods of opti-mal damage to occytee in the human females a) During oocyte prollieration in the female fetus, when all occytes undergo meiosis until y i the first meiotic prophase wherein they are " frozen" until ovulation. b) During ovulation, when oocytes develop one or two at a time into mature eggs ready for fertilization. Although DNA adducts may be formed in the human fernale oogenic tissues at other times, there is adequate opportunity for faithful DNA repair 'during the 12 - 40 years of the pro-longed first meiotic prophase. In the human male, however, spermatogenesis is continuous following puberry, and germline cells are constantly sensitive' to radiogenic damage We now know of over 7,500 birth defects which afflict the human race. Most of these are recessive, that is, it re-quires inheritance of two afflicted chromosomes to make the disease manifest. An exception is in the X-Ilcked disorders which are uniformly expre ssed in the male since he inherits a single X chromosome from his mother which is unpaired by any paternal contribution. Mutagenic studies in Drosoehila populations reveal the startling finding that many recessive mutations do not appear for 10 or 20 (up to 50) generations. There are two types of synergy at work bere a) The phenotypic synergy which occurs when two heterozygous carriers of a genetic de-ficiency, neither bearing the disease, bear children who are homozygous for the defect. { b) The synergy of cumulative genetic Lasults to the gene pool carried through successive generations of a species. I Mankind is particularly privy to the latter synergy in that modern medicine is aengenic. Our species no longer is guided by inhumane " survival of the fittest." Many sur-vive who could not have a decade or certaLnly a century ago through prostheses and intensive care. Hence our gene pool i is becoming replete with mutations. Birth defect-induced j maladies occupy at present fully one-third of our hospital beds. The population residing near TMI has been exposed on two previous occasions to large radionuclide releases from TMI-2. yleid votes captured during the krypton-85 venting in July 1980 showed accumulation of the radionuclide in their 4 testicular fat (see Tigure 2 and substitute spermatogenic tissues for breast tis sue). Xenon-133 has similar lipophilic properties to krypton-85 and there is no reason to assume that similar uptake occurred in field voles and humans d. iring the initial stages of the accident la March and April 1979. w w - w ee,, .w.-7 v c, ,,v.w-e,-,e, -,---wwv~,-9,,-.t ,.,--we ,e--,a e,we. + - -, e

h I. e ',l Melholt - 9

3) A summarv of radionuclide releases' at Three Mile Islandt Past and future

~ In its order for a hearing of August 9,1979, concerning the restart of Unit 1 at the Three Mile Island Nuclear Station, de Nuclear Regulatory Commission clearly defined its reasons. for holding these heart:gs: - That sufncient prote. tion of the public from radiologic hazards be guaranteed. Asy realistic assess =sent of radiologic hazards to TMI area residents from the TMI-1 restart cannot be done in a vacuum, but must be -done within the context of au radiation releases, past and plarmed for.. the future, to reside =ts 'of de TMI area because of the more dan cumulative nature of sequential carcinogecic and mutagenic risks frem discreet radiation exposures, as outlised cf. previous pages. Putting petectial. TMI-1 radienucude releases i=to the ce= text of total releases to the area, both past and imminect, may be summarized as follows: water a) Initial dumping cf 265,000 gances of centa=icated water into de Susquehansa on 11 arch 30, 1979. b) IFICCR-C resics cc taminated wi6 = cst el the radionuclides which.were depcsited - en the. floor of the' auxiliary building (stered in 1! ers and concrete bunkers en ie Island) and r e s ulting 450,000 galices cf tritium-contam1:sted water (which the utility has preposed te dumped into the Susquehassa River). 4 c) Cleanup cf 700,000 gances of highly cen-taminated water in the ecstai ment building sump. using de zeelite-submerged deninerall:er system (505). This step is imminent. Disposal of both zeolites' and residua 11y contaminated water is an } unsolved problem. I E 4 j b d) Cleanup of the highly contaminated primary 1' l coolant water (95,000 ganons); to be accompushed 4 after core removal, i Air e) Noble gases and other radionuclides which escaped. filtration during de isitial stages of the accidset, March-April 1979. f) Krypton-8 5 and traces of stt octium-89/90 } intectionally vected from the containment building atmosphere, June-July 1980. Core g) Dissection and removal of 100 tons of partiauy melted fuel rods, penets and oder amal-gamated assembly. As many of the fuel assembues as practicable win be removed through the fuel. canal as in normal defuelleg operation. TMI-I h) Potential radiocuclide emissions into air or water as the r,sult of normal operation or various types of accidents. t i e .,,.m-_t n-w w-

t ---3. .im u - s. s. C :::h s ic r. This hearing iefere de A::=1: Sale:v and 1.1:er. sing 3:ard was ciarged is de *iEC : der cf A g:s: 9, 19 c. wie deter- -N g if "pc:e :Lal L::e:actics be wees Tait I a nd da.a g e d Une 2" cc;1d exis: (first spe cift: c:::ers, las: paragraph, page 41.

.Sch :? dis hearing ha s :::cer ned pete=ta!

• • its 1 a:d 2.

~~se p:in physical 12:e:a: ic:s herwee: 1 my te sti===y here is da: U:i: 1 and de > > -= ged Osi: 2 are definitely MeierhalFr ::::ectef, a d 11: ils ::::e:- tic =:s: he a:iequately ::dersteed and a::::::ed I:r is any ; lass hr TLC-1 restart. I: I?-7 (ICN? 2-3) de ION? has validly ::=e:ded dat de CPU Imerge:cy Fla: hr TLC-1 is deficies: i.: ::: sider. 1:2g de c:=clative dese er :::11 dese c c-- + =e : is ;:s assess =es: Of public he**.i hazards P.ich may arise fr:= pcte::ial ra di== lide re.e:se s. .se frarti: Of PAC este-g:::es ci radi:1 gic emerges ies are measiegiess !:: de T2.C ::-- - - f:7 L: ias:

1) R e s id e :s._.ay hav e b e en ex e s e d ::

radia:i: 1evels is excess :I Ceneral Imer-g e s *r, e V e., s a.r e aO*f a s *

• e s u.:

C., de ac:ide= at TLC-2. 21 7:e = s: r a die s ensitiv e phu e :1 h -- = - de v el:p=e:. de feras, is ign:r ed 2 ie:e :al: 12:ic es.

3) The fra:-icca; FAC v2;;es ne :::

ci: s ely a'. lie d :: te ci any prac:::al vahe

. :. g a:y a:::a; adich;it e=e r ; e ncy.

4i The p:hile r e s idic; c e a r *-::e e Mile Is! :d has been predispesed :: bei radia, tics-ind:ced ca eiceges;:i:-r and biri deie::s. t

5) 0:se :--

u:=e=s a s us e d '- "e ~ vr.~:=ergency r.a may b e ::,.e r e s:.= ate s by crders cf mag:it de 'f tra:sfer fact::s fr = TLC-1 : searby reside::s are re-

• seidelberg Reper.

assessed ac erding :: de

f.' Molholt - 11 EP-10 (ECNP 2-28) ? Appendix D of the Plan contains reference tn the need for the decontamination of radiologi-cally contaminated individuals 'p.16) but does not provide any information as to how many people may be contaminated, the kind and de- ~ gree of contamination expected or te be planned for, or the number of facilities and medical personnel appropriately trained in decontamination and radiation injury treatment techniques which may be necessary. It is vital for both worker and nearby resident populations that appropriate biological monitoring and decontamination procedures be well worked out in advance of TMI-1 restart. The entire. testimony of the previous 10 pages attests to the special predisposition of these populations to damage induced by any.radionuelldes released from TMI-1 duri.ng either normal operation or in the event of an emergency. The Plan must take into account three overtly sensitive segments of the population residing or working in the TMI area:

1) Those individuals who are predisposed to radiation-induced carcinegenesis or mutagenesis due to prior radiation exposure (e_.1., to radio-nuclides released during the accident at TMI-2 or subsecuent radionuclide releases).

2) The human fetus.

3) Individuals who are homozygous or heterozygous for one of the following genetic diseases a) xeroderma pigmentosum b) ataxis telanglectasia c) Bloom's syndrome d) Tancoc.i's anemia.

l In that radiation monitoring off-site cacaot detect these in-dividuals, it is suggested that the Plan include provisions for Ladividual radiogenically induced cytogenic monitoring La the i event of accidental releases during a radiologic emergency. l The advantage of this technique is that it is personal; it uses an individuals own white blood cells to modtor chromosomal damage to tne individual resulting from radiation exposure. i I Radlations have been shown to induce cytogenetic abnormalities i j La proportion to pre-carcinogenic or pre-mutagenic events in human subjects. The CPU Emergency Plan falls to take into account different eusceptible groups within our population to radiation-induced genotoxic effects and should make provision for protection of these groups. i ~

0 ~ Molhoh - 12 E*P-11 (ECNP 2 -3 3). The BRP plan,(AppeddLx 8) relles on the infant thyroid dose (1.5 rem) as the dose ir im milk ingestion to be avolded (p. IX-4). This does not take into account the fetus, whose sensitivity may greatly exceed that of the infant. In addition,. the value of 1.5 rem to the thyroid from milk 3 ingestion does not take into account the inhalation exposure. Whereas the previous pay, of my test! mony pertained to all radienuclide exposures, this section refers specifically to j exposures to one radionuclide', iodine - 131 /132. (During - the early stages of radionuclide releases of fission products the iodine-132 contribution can outweigh that of Lodine-131. In addition, the hypothyroid inducing potential of the two isotopes hae been found to be synergistic rather than addi-tive. ) For the sake of brevity. I will refer herein only to Lodine -131. This section of my tsatimony, relevant to ICNP contention EP-11. will consist of four parts:

1) The special sensitivity of the fetus to Lodine-131 induced hypothyroidism.

2) Deficiencies in the Bureau of Radiation Protectica Plan.

3) Evidence that normally operating nuclear stations release considerable iodine 131.

4) Conclusions.

1) The secclal s ensitivity of the fetus to todine-131-induced hvoothyroidism.

Depending upon the stage of hwnan fetal development l (week of gestation), the human fetal thyroid gland is up to 200 times more sensitive to hypothyroidism induced by lodine-131 than the adult thyrold. This exquisite sensitivity of the l fetal thyroid to Lodine 131 is a product of both the higher j affinity of the developing thyroid gland for lodine and the ( greater sensitivity of rapidly dividing tissues to radiation-induced damage. Since the thyrold hormone, thyroxin, requires 3-4 I atems of lodine to be functional, all isotopes of lodine, in- { ciuding 131 and 132, are scavanged by the developing thyrold gland. Disturbance of thyrold function is serious, especially in the developing fetus, since thyroxin is required for normal skeletal development, including the skull. Fetuses with in-sufficient thyroxin are born with a form of cretinism which may be accompanied by mental retardation and eventually death due to smal cranial capacity. For this reason, neonatal hypo-thyroidism has been checked as a birth defect in all Pennsylvania i newborns since mid-1978. a b s- --n

~ Melholt - 13 There is some evidence that s ufficient. iodice-131 leaked from the TMI-2 nuclear station.during the accident in March-April 1979 to. inducci an excess of neonatal hypo- ~ thyroidism. This evidence is relevant to ThC-1 restart in dat the same area residents were affected and as I shs11 discuss fureer in section 3, there is evidence that normally cperating reactors release significam amounts of lodine-131. There are three types of evidence that TMI area residents suffered considerable contamination with lodine-131 during the TMI-2 accident and subsequent increased levels of neonatal hypothyroidism. a) There was a significant increase in rates of neonatal hypothyroidism downwind and down-stream from the TMI-2 nuclear station in the nine months after the accident. b) Field votes trapped in de dird week of de accident contained significant levels of iodice-131 in their Syroids. c) Calculations frem noble gas / iodine ratios indicate dat 5,100 -64,000 curies of lodine-131 may have been released. a) Henatal hvecthvroidism after TM12 The normal rate of neonatal hypothyroidism in the U.S. is 1/4,300 live birds, a rate that has been seen in Pennsylvania as a whole since te sting began in mid-1973. In Lancaster County, hewever, f olicwing the TM1 2 acci-d e nt between March 28 and December 31, 1979, tere were 6 cases of neenat:.1 hypothyrcidism in 2,7C0 live b:rms. This is ten times de expected number of cases of dis birs defect. The City cf Lancaster receives 8 million gallocs of drinking water each day less than 10 miles downstream from the TMI-2 nuclear station. Downwind from the TMI-2 nuclear station, a statisti-cally higher number of necnatal hypothyroid births was also r seen in the nine months fcuowing the accident. The pattern of neonatal hypothyroid births m Pennsylvania before and after i the ThC-2 accident is seen in Figure 4. Since the predomi-sant wind direction fonowing the accident was northeast, th9se counties centiguous to and including Dauphin in the northeasterly direction are compared for neonatal hypothyroid births during the nine mcaths before and after :he acetde'st (Table 1). Wher ea s l Dauphin, Lebanon, Berks, Schuylkill, Lehigh and Carbon coun-ties had two cases in the nine mcnths before the accident, there were eight cases in the nine months after. Other sections of Pennsylvania (west of Harrisburg, the five county Philadelphia area) had comparable rates before and after de accident. Hence, these unusual inciden:es of neonatal hypothyroidism are associated both temporany and geographically with the time of de a c cident and the place of Tlace Mile Island. In addition to incres.ses in hypothyroidism, there was statistically significant increase in infant mortanties within a a ten mile radius of TMI-2 following the accident (Table 2). s 9 A

) 1 i i Melholt - 14 b) Animal studies Three different types of animal studies were done in the TMI area a.fter de accident March-April 1979 to determine potential contamination with iodine-131. These were mediated by Minersville State Conege, de University i cf Missouri and de NRC. The results of de dree studies are summarized 1.n Table 3, ""he MincnvL :nm captured field voles at dree s it e s. about 20 voies per site. Voles captured during the dird week of the accident 1.9 km northeast from de reactor had a mean value cf 1866 pCi/g dyrcid (maximum, 3300 pCL/g or 3.3 nCi/g). Voles captured 2.3 km to the east had less dan haU de nordeast populations' mean iodine-131 content: 73 3 pCL /g thyroid tis sue, whereas voles captured 12.9 km to de nordeast showed no appreciable lodine-131 in deir dyroids. Maximauy these veles could have received 420 mre= thyrcid exposure calibrated to April 9th. These findings are substantined by the single vele captured by the Univer sity cf Missouri team 0.8 km east of de r e a ct o r. This vele ec=tained 0.53 pCi/g whole body weight (1500 pCi/3 mg thyroid) iodine-131 calibrated to April 25th (abcut 6000 pCi/g !! calibrated to April 9th). The Cniversity of ' Missouri team aise analyzed de dyroids of three rabbits captured 1.6 to 4.3 km certheast of the TLC-2 nuclear statien en April 244 " e pceled dyroid samples showed 644 pCi/g when calibrated to April 96. As compared to de NRC cow and goat milk samples of de same perica (36 and 41 fCi/ml. r e s pe ctiv ely), the Held vele and rabeit dyrcid gland samples shewed ave crders cf magnitude more activity en a weight equivalent basis. The expe rime nts show the poor sensitivity of =tik to envirenmental centamination by iodine-131 and may explain the NRC's under-estimatica cf the extent of iodine contamination fenowing the accident at ThC-2. U one anews for the iodine-131 and -132 levels during de initial phase cf the accident at ThC 2, and for the greater sensitivity of de fetal dyroid gland to iodine-131, it may be calculated dat the 3.3nC1/g iodine-131 seen in voles is s uffi-cient to induce neonatal hypcthyroidism (Table 4). c) Calculatiens of todine-131 release at TMI-2 l Official estimates of 14-26 curies iodine-131 release at ThC-2 during the course of the accident may be orders of magnitude to low according to Takeshi. Utinzing the ratio of noble gases to iodine-131 on April 20th (when the noble gas monitor s dropped by onto scale), Takeshi derives an iodine-131 release of 5,100 curies (Table 5A). On the other hand, if the release rates of NURIC-0600 are utilized. Takeshi derives total iodine-131 released during the TMI-2 accident as 64,000 curies (Table 53). In summary, censidering de higher iodine-131 release levels calculated by Takeshi and the hypothyroid-inducing levels m

f. Molho12 - 15 of iodine-131 found in the thyr;id glands of animals trapped during the accident, it is plaustble that the statistically signi-ficant increases in neonatal hypothyroidism seen in human births near the ~'MI-2 nuclear station after the accident were dae to human exposure to Lodine-131 from the reactor. These considerations are critical in the consideration of TMI-1 restart, for, as 1 shall document in section 3, there is evidence for considerabic Lodine-131 from normally operating nuclear staticas. Since the TM1 area residents ha ve already been exposed to todhe-131 as a result of the TW '.-2

accident, this tsetope must be monitored with extreme pracision if TMI-1 is to go back online (see section 4).

This required precision for the prote: tion of the health of TMI area residents is lacking in the Bureau of Radiation Protection Plan.

2) Defic!cncies in the Bureau of Radiation Procection Plan Considering potential lodine-131 doses to infants, the 3RP Plan is deficient in three areas a) Milk is not a good monitor for iodine-131.

b) The stated thyroid dose to be avoided (1.5 rem) is at least an order cf magnitude to high LI we consider the fetus, c) Iodine-131 may be inhaled as a gas in additicn to being ingested. P-tor to the restart of TM1-1, this Plan must be augmented in order to truly pretect the public frem potential adverse effects of releases from the nuclear station. 1.ack of such protection f or the Unit 2 nuclear station may have resulted in the neo-natal hypothyroid and infant mortality increases seen following the accident. i a) Milk a s iodine-131 mer" tor I i l On a weight equivalent basis, milk is five orders of l magnitude less sensitive than field vele thyrolds in todine-131 l monitoring of the envirocment. The use of milk for monitor-ing of environmectal centamination by radionuclides is appro-priate for strontium -89 /90 and cesium-137, which mimic calcium in their chemical properties and are therefore quite prevalent in milk. Extensica of this device for measure ments of iodine-131 levels, however, is strained at best. More appropriate monitoring tools, such as caged or feral small mammals, should be employed for iodine-131 levels rather than antequated sampling of cow and goat milk. b) Fetal hvoers ensitivity to iodine-131 in addition to inadequate iodine-131 monitoring, the BRP Plan indicates a level of this radionuclide not to be ex-ceeded which is at least an order of magnitude above a neo-natal hypothyroid dose. The fetus must be regarded as a helple ss lifeform, exquisitely sensitive to iodine-131 trauma.

e f Molholt - 16 For the safety of the fetus, it is suggested that the thyroid do s e not to be exceeded in the 3RP Plan be changed from 1.5 rem to 150 mrem-c) Inhalation dose By its concentration on iodine-131 1cvels in milk, the 3RP Plan considers solely tee ingestion pathway for human contamination by this radionuclide. Significant contamination of humans, including pregnant mother s, can occur by inhalation of iodine 131 while it is contaminating the ambient air as a gas (its native state). Inhaled iodine. 131 is readily dissdved in de blood and adsorbed by the thyroid gland. Ag ain, this defect la the BRP Plan would be obviated through use of s:rall mammals as monitors for lodine-131 contarnination. In summary, the emergency plan of ie Bureau of Radiation Protection is flawed concerning protection cf de public from iodine-131 which might emanate from TMI 1. The Plan relies on milk as monitor and fails to consider either the enhanced sensitivity of de fetus or inhalation r oute s cf exposure to iodine-131. This section of *he 3RP Pla must be revised before de public will be protected from potential iodine-131 releases at TM1-1.

3) Evidence that no rmally coeratinc nuclear stations relea s e considerable iodine-131 Although the iodine - 131 releases may have been underestimated by crders cf magnitude at TMI-during ie a c cid e nt, Gis was clearly not durtng normal operation.

%"nat is the evidence that normally operating statiens re-lease dangerous levels of Lodice-131 ? The first evidence comes from de Savannah River i Plant in South Carolina. Atemic Energy Cc==is sion docu-ments for years reported a levels of iodine-131 contamina-tien of the envir onm ent surrounding the Savannah River Plant. g l Yet r e c e =t declassified documents showed dat the extent of iodine-131 release was 2,500 curies between 1955 and 1961. This was a period of presumably normal operation at the nuclear plant. The second evidence that normally operating plants may release hypothyrcid-inducing amounts of iodine-131 comes from closer to heme. Earlier I cited de 6 /2,700 frequency of neonatal hypothyroid births in I ancaster County between March and December, 1979, as being ten times the expected rate. Paradoxically this high rate has cont!nced into the first eight months of 1980. This is lcng after lodine-131 from the TMI-2 reactor would have dissipated and decayed. However, Lancaster County is just east (downwind) of York County, which contains the Peachbottom nuclear stations in its south-east corner. This is an old nuclear power plant of the 1 dian Point reactor vintage. Could it be leaking significant iodine -1317

1 s e Molholt - 17

4) Cenclusions e

Considerable information is available ' about hypo-I ~ thyroidism induced by lodine-131 as a fission product from -{ the studies of the Marshallese ' and frem the Baseberry Event l in Utah (both in the 1950's). We understand what can happen in both man and animal when exposed to high levels of iodine-131. A functional thyroid gland is required for good childhood and sdult health and absolutely vital for the fetus. Unlike al- - most all other radionuclides, LodineL131 zeros in on caly one target organ, the thyroid, and, il present during critical periods of development, in sufficient concentration, this radionuclide can ablate thyroid developr:mnt. There may have been considerable contamination of the TMI area by lodine-131 during the accident at TMI 2 which caused significant health problems to develop in human fetuses ja, utero. There is suspicion that TMI-1 as' a normally. operating nuclear station may emit lodine-131. Definitely in the case of a radiologic emergency this radionuclide will be among the most dangerous. It is therefore crucial that the l Bureau of Radiatir.n Protection ensure public protection from further exposure to Lodine-i31 in de area around Three Mile Island. Concerning its plan to protect citizens h-om iodine-131 exposure at TMI-1, the 3dreau must revise its menitering p ogram, it is suggested to include small mammals as sensi-tive probes for the radienuclide. Dese allewances should also r be tightened by as crder of magnitude in consideration of the exquisite sensitivity of the fetal thyrcid to iodine-131 damage, 4 J I f l w l { i i I h' ) 9.,*- ' * = * ' 'h [ " 4 4.- ,4.. e n -p g e a b t -, - - -., ~, e ,,,e

1._ Molho12 - 19 References e i -I Molholt, B., J. A. Dorsey and J.R. Kohr (1980) j Final Invironmental Assessment for Decontamination cf the Three Mlle Island Unit 2 Reactor Building Atmosphere. NUREC - 0662, Vol. II, pp. 136 - 209 and 511 - 514. Dorsey,. J. A. and B. Molholt (1981) Final Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Waste Resulting from March.28,1979, Ac cident i Three Mile Island Nuclear Station, Unit 2. NUREC - 0683, Vol. 2, pp. A-209 - A-237.

Franke, B.,

E. Kruger, B. Steinhilber-Schwab, H. van de Sand and D. Testfel (1980) Radiation Exposure to the Public from Radioactive Emissions of Nuclear Power Stations. Wis senshaft Aktuell, nr. 2, Feb., pp. 39 - 47. B eie rwalte s, W.H., H.R. Crane, A. Wegst, N.R. Spafford and E.A. Carr, Jr. (1960) Radioactive Iodine Concentration in the Fetal Human Thyroid Cland from Fall-cut. J. Amer. Med. As sa. O, 1895 1902. MacLeod, C.K. (1981) Some Public Health Lessons from Three Mile Island. Ambio M, 18 -2 3. Field, R.W., I.H. Fleid, D. A. Zegers and C.L. Steucek (1981) Iodine-131 in Thyro!ds of the Meadow Vole (Mieretur sennsvivul-S;u) in the Vicinity of the Three Mile Island Nuclear Generating Plant. 3 Health Physics Qn, cre ss. Au;;ust issue). Takeshi, S.. (1979) NRC's Cross Underestimation of the Radioactive Releases and Po;ulation Doses during the TMI-2 Accident. Nuclear Engineering, Vol. 26, No. 3. i l l l 4 } l l 1 f i i

9 q =

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• Molheit - 19 Figure 1.

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s p w +s % a #g e,s s e. n. w m,ggip ~.- g u mg mn,q.~ raw ,n 2-w JFQ*'%sy** #.;.7sN:Q* ',,,,a 'ss i/ A

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i i .Q,' ~ _ - ~ Molholt - 21 Tigure 3 2%w%g .. $ gp Y F W 3L ky $ J"x '"fC~ O_.s c.uw y,N T / h g% ' %. :k $ Jn ~ ** *l,fy.,n j s g % yJ g # a n i j 7 0 l' i \\,t e s s Two'inatograptu of am induced chromosome aben Oons in human personeral Wood lymonocytna. The enenacons sun incuos: 0,dicantncs (two esmramemd: F, seemns tregments Ino centromuml; T. recsoroom trundocssons isnitt of comomere t: and R. nngs. ca.n.w.m m s re e-

l s s 8 ~ -.x,. mi =YAMSW I Molholt 22 Fleure 4 INCDENCE OF NEONATAL HYPOTHYROIDISM June 20,1978 - March 28,1979 /. _I f k ~~ l u" 1_m_ m A \\ / 3 m '"\\ u e =-(~ ~ 5 '^~,-i_ W c

• W-c) (" " y /

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• Neonatai Hvret. m:cen Case Cam Reponed 9y B Nuccar Power P! ant Cgarement oi Hea.th INCDENCE OF NEON ATAL HYPOTHYROIDISM March 28,19 9 - December 31, IF9

/ [e._ I ~ f l l \\ k \\ ~~ _ /- c n t _ s==-- ,--. x f 1/ ~ 5 9 =~ %) fx f { - i . 1*,L_ g [g '.cf..a.g .g 2 _.. s. \\ N, s [ w Q pbtQ d.,/ l' PENN$YLVANIA e Neonatal Hypothyroidam Case Cases Reponed By i M Nucear Power P! ant Depanment of Health \\_ ' ~ ~ ~

+ q h -. ~w,. : - Molholt - 23 Table i NEONATAL HYPOTHYRCIDISM During the nine months before and after the accident Ceograchic Area Before A.ft e r Pennsylvania west of Harrisburg Five county area 6 6 cf Philadelphia Rest of Pennsylvania 4 14

• Tctal 17 27 Downwind TMI

( Da uphin, Lebanon, Berks, 2 8* Schuylkill, Lehigh, Carbon) I f l Downstream TMI (Lancaster Coccty) 2 6

• Difference significant at p < 0.05.

4 ,yy .<eee. e e= M

9 e, .g.~. , -- -- m- ;; m:ux. Y Molhelt - 24 k i F k h Y Table 2 1 D& ANT MCRTAI TIES 'ATr}CJ 5 CR 10 MII.IS ' CT TM 5 mile radius 1977 1978 1979 no. deada 3 1 7 l rate /1000 birds 6.7 2.3 16,1 10 .ile ra diu s 1977 1978 1979 r.c. deais 20 14 31 rate /1000 birds 10.5 7.2 15.7 + l 1877 73 averare v. 1070 i i ( 1977-78 1979 so. deads, 5 mi. 2 7 I E no, deads,10 mi. 17 31 d

• Di!!erence significant at p

< 0.05. e- +'NhemM6.r e M w,w - pW e e' & n+ oppw p-w e-e m ---3 y y -w p

?. f

g. :r -

-~ -.--.......u Molholt. 25 Table 3

SUMMARY

OF ANIMAL STUDIES - IODINE.131 IN THYROIDS Tield Votes Site Numbe r Mean ^ Max _ Mean mrem (per thyroid) (per gram *)- 12.9 km NE 20 0.0 1 0.2 pC1 April 6 16th 2.3 km E 22 2.2 1 1.1 723 pCL 62.5 1.9 k:n NE -18 5.6 1 1.2 11.4 1866.(4/9). 210

• assuming 3 mg / thyroid April 25th 0.8 km E 1

' 0.53 (4/25) (1500 ) Rabbits April 24th 1.6 to 644 (4/9) 72.5 4.8 km NE 3* 161 (4/24)

• composite sample not counted until May 9th Cow Milk Max I /ml) 36 fCL

+ Coat Milk 41 Is oeleth s [O l 1.9 km NE 18 1866 pCL/g in field vole thyrolds is conservatives i

1) Maximal values were 3800 pCL/g (3.8 nCL/g).

2) Thyroids may weigh less than 3 mg.

i

3) Calculations are to April 9th when maximal I.131 releases were March 28 - April 1st.

4) Only I 131 calculated (early 1 132 mrem may have exceeded I-131, they are synergistic)

5) Tetal thyroids 10 200 X s!.flaity for lodine.

l 1

= I i m. . owe v n. --w .T.,' - mTJ;O.Y/ ~'~-3 ~ ~ ' ' ' 26 Melholt -- ~ Table 4 NECMATAL HYPOTHYRCIDISM AND IODINE-131 AT TMI CONSIDERATIONS

1. 4 nCi/g max in voles,

1. 9 km NE 2.

8 nC1/ g (4/ 9 ---> 4/1.70) 3. ---y 80 C1/g from equivalent I-132 (I-132 9X I-131) 4 ---> 16IO nC1/g because fetal thyroid 10-200 X uptake I-131 (16 pC1/g)

5. 50% suppres sion of rat thyroid with 13 Ci/g I-131

6. the refore, potentially hypoth/roid -inducing dose released at TMI t

l i i t a

4, -w m **~04ut;"rM W-m.* 'rE r ~ ~?ShS.~N'*0 'U~!?_ ? ~~ ^ Molholt - 27 Table 5 RE EASE CF IODINE-131 AT TMI (Takeshi) A. Caleclation from I-131 and noble gas releases on April 20th

1. I-131 release rate = 1. 4 g1/ sec

2. noble gases released at 4,700 gi / sec

3. I-131/ noble gases = 1 / 3400

4. Extrapolation to March 28th: 1 131/ noble = 1/ B300 6

5. Total noble gases released = 45 x 10 Ci 6

6. Therefore, total I-131 released = 45 x 10 /3300 = 5100 C1 3. Caledation frem NURIC-0600 (NRC Cffice cf hspection and Enf o r c eme nt, Aug. 1979 "bvestigation into TMI accident")

1. I 131 releases began 7 a.m. March 28th

2. I-131 to noble gas release ratio then = 1/ 700 l

l

3. Maxinul iodine releases occurred within a few hours i

6 4. Therefore, I-i 31 r elea s e = 45 x 10 /700 i = 64,000 C1 C. Admitted release of I-131 = 14-26 C1 m}}