ML20127C065

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Responds to Chilk 840827 Staff Requirements Memo Re Radiological Concerns Raised by Aamodt at 840815 Meeting. Surveys Re Effects on Human Health & Plant Life Following TMI Accident Not Scientifically Conducted
ML20127C065
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/07/1984
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Asselstine, Palladino, Roberts
NRC COMMISSION (OCM)
Shared Package
ML20127C068 List:
References
FOIA-85-8 M840815, NUDOCS 8409190111
Download: ML20127C065 (10)


Text

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3' v SEP 0 71384 fiEMORANDUM FOR: Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Comnissioner Zech FROM: William J. Dircks Executive Director for Operations

SUBJECT:

STAFF ACTIONS FROM THE AUGUST 15, 1984 COMMISSION MEETING ON TMI-1 (M840815)

PURPOSE: To respond to Secretary Chilk's August 27, 1984 Staff Requirements Memorandun (M840815) regarding the radiological concerns raised by the Aamodts at the August 15, 1984 Commission meeting.

DISCUSSION: Secretary Chilk's August 27, 1984 memorandum requests that the Staff prepare a response to six concerns raised by the Aamodts during the August 15, 1984 Commission meeting.

These concerns pertain to effects on human health and plant life following the TMI accident from radiation levels in the TMI area which allegedly were much higher than reported at the time of the 1979 accident, and to subsequent coverup of these radiation levels by the licensee, the NRC, and others. The 'Staf f responded to some of these concerns in 1984 memo from W. Dircks to the Commissioners.

- 6) The the AuguQ's Staff responses to the remaining concerns appear in Enclosure (1) to this memo.

The NRC staff has examined the Aamodt Report and finds that the survey was not scientifically conducted. Nevert heles s, the Staff has looked beyond the scientific quality of the survey to see if it contains a body of information that would warrant further investigation; we see no such new information. Recognizing that the objectivity of the NRC

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The Chairnan and -E-Connis sioners is being challenged here, the Staff prepared a letter to the Centers for Disease Control, which was forwarded with the August 31,19R4, memorandun, to seek an independent opinion.

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. Dircks Executive Director for Operations

Enclosures:

1. Staff Responses to Aamodt Concerns
2. Sept. 20, 1979 Letter fm Denton to Reed cc: w/ enclosures OPE .

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Enclosure 1

. Staff's Responses to Aaaodt Concerns Listed below are the Staff's responses to the six items (underscored below) addressed in Secretary Chilk's memorandum of August 27, 1984.

1. Botanical data on plant abnormalities which, the Aamodt's believe, suggest that the plants were exposed to radioactive fallout.

Surveys performed by the Pennsylvania Department of Agriculture after the accident at Three Mile Island, Unit 2, have failed to detect any unusual vegetation effects which could be attributed to airborne radio-active contamination resulting from the accident. After analyzing 187

, plant specimens submitted from Dauphin, Lancaster, and York Counties for 1978 and 1979, the Pennsylvania State Plant Disease Clinic found that the damage to 90% (168 specimens) of the specimens was attribut-able to normal biological or environmental factors. Three percent (6 specimens) were inadequate to analyze, and the causal agent of the problems for the remaining 7% (13 specimens) could not be specifically i denti,fi ed. These and other findings of an NRC investigation of reported plant abnormalities in the TMI Area are documented in NUREG-0738, Investi-gations of Reported Plant and Animal Health Effects in the Area of Three Mile Island. This report found that "all vegetation stress was attribu-table to natural causes."

2. Health related effects data which, the Aamodt's believe, suggest that people in the area of TM1 were exposed to radiation levels higher than _

reported at the time of the 1979 accident.

The Staff has prepared a summary of the scope and principal findings from the more significant studies performed on potential health effects i

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resulting from the Three Mile Island, Unit 2, accident. This summary (see Enclosure (2) of the August 31, 1984 memo from W. Dircks to the Commissioners) includes information on the maximum radiation releases and estimated radiation doses to the population living within a 50 mile radius of the Three Mile Island fluclear Plant. Contrary to the Aamodt's conclusions, this summary indicates no health effects directly attri-butable to the radiation from TMI.

3. Action taken by NRC in response to the August 8,1979 letter from Pennsylvania State Representative Steven Reed to then-Cnairman Josepn M. Hendrie.

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Enclosure (2) to this memo is a copy of a letter dated September 20, 1979 from Harold Denton, Director, Office of Nuclear Reactor Regula-tion, to Pennsylvania State Representative _ Steven Reed. This letter is in response to the August 8,1979 letter from Representative Steven Reed to then-Chairman Joseph M. Hendrie, and indicated the symptoms discussed were not possibly due to radiation exposure expe-rienced from the TMI accident. In fact, they were somatic symptoms of psychological stress experienced by people in the vicinity of TMI, post-accident. This psychological stress is one of the most widely studied aspects of the TMI crisis, and its effects have been reported and discussed widely in the medical literature. -

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4. Any group or organization presently performing an epidemiological study of persons wno lived near TM1 at the time of the acciaent in Marcn 197s.

Shortly after the Three Mile Island, Unit 2, accident, the Governor of Pennsylvania designated the Bureau of Health Research of the Pennsylvania Department of Health to coordinate and manage all health-related research activities relative to Three Mile Island. At the same time, a special Advisory Panel was commissioned by the Secretary of Health to oversee and guide all Three Mile Island-related health studies administered by the Bureau of Health Research. Some of the studies which have been or are currently being conducted in this area are:

TMI Census Pregnancy Outcome Study Congenital / Neonatal Hypothyroidism Study Radiation Dose Assessment Study Health Behavioral (Stress) Study ,

Mental Health Study Infant Mortality Study Health Economics Study Mobility Study Findings from the completed studies on congenital / neonatal hypothyroidism and infant mortality (Tokuhata, G., " Impact of TMI Nuclear Accident Upon Pregnancy Outcome, Congenital Hypothyroidism and Infant Mortality," chap-ter prepared for Energy', Environment and the Economy published by the Pennsylvania Academy of Science,1981) have shown that the Three Mile Island nuclear accident was not responsible for the reported cases of -

congenital hypothyro'idism, nor did the accident have any demonstrable impact on infant mortality in the TMI Area.

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4-In addition to these studies, the TM1 Advisory Panel and the Secretary of Health have recently approved a program to establish an Epidemiologic Surveillance System (Tokuhata, G., "Epidemiologic Surveillance in Penn-sylvania:

A Case of Nuclear Power Plants," Pennsylvania Department of Health, June 1984). The objectives of this system are to develop and implement a baseline health information system for the population resid-ing within 20 mile radii of the six nuclear power plants in Pennsylvania, and for selected control areas.

As part of the settlement of a 1981 federal class-action lawsuit against the owners of Three Mile Island, 5 million dollars was set aside to establish a TMI Public Health Fund. The objectives of this fund are to study the health consequences of the Tlil accident and par-ticularly of the effects of low-level radiation on people.

5. A list of the scientific studies of probable exposures and health ettects resulting f rom tne 1979 accident.

The Staff has compiled a comprehensive bibliography of the studies and surveys that have been performed regarding radiological inpacts of the Three Mile Island, Unit.2, accident. This bibliography, arranged in chronological order, was provided as Enclosure (1) of the August 31, 1984 memo from W. Dircks to the Commissioners. _

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in Atlanta to conduct an epidemiological ease Control (CDC) st dThe us there are health effects that can be attributu y to aetermine if released during the TM1-2 accident. ed to the radiat1on

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The Staff has previously investigated the feasibilit y of conducting epidemiological studies on large population groups .

Soon after the TMI accident, the Staff initiated a contract (with Health Syst Equifax,Inc., Reading,MA)to: ens Division,

1) study the strengths and constraints in conducting epidemiologic studies of subject s with low-level ionizing radiation exposure; and 2) to examine the merit ies.

of conducti ng such sted-The findings of this study are contained in ,NUREG/CR -

The 1728 Feasibility of Epidemiologic Investigations of th Low-Level Ionizing Radiat' ion. _ e Health Effects of This study considered investigations of several large population groups (including workers in health services, nuclear power plants (including the TMI worker populati on), Department of Energy-su'pported facilities or nuclear shipyards

, and people who received routine pre- or postnatal radiological exami clusions of the study were that: nations). The con-

"no out-standing candidate population is available

--one that presumably could be used to define with reasonable uracy acc the low-level radiation-induced riskEven . of cancer if the lar' gest of the candidate populations, the were proba-studied .

bility of detecting a statistically significant r be very small (<60%). esult would Therefore, the decision whether to conduct a study must rest heavily on social and political

considerations rather than on scientific ones. it may be worth 15 or 25 million dollars to demonstrate that the health effects are so small that they cannot be measured, and that on this basis the present regulatory standards are adequate."

The NRC staff has examined the Aamodt Report and finds that the survey was not scientifically conducted. Nevert; ~.ess, the Staff has looked beyond the scientific quality of the survey to see if it contains a body of information that would warrant further investigation; we see no such new information. Recognizing that the objectivity of the NRC is being challenged here, the Staff prepared a letter to the Centers for Disease Control, which was forwarded with the August 31, 1984, memorandum, to seek an independent opinion. The Staf f will review the findings of the CDC and make a decision at that time as to whether fur-ther epidemiological studies of the THI Area population are warranted.

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