ML20128B674

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Responds to NRC 850516 Memorandum & Order CLI-85-08 Denying Aamodt 840621 Motion Re Airborne Radioactive Releases from 790328 Accident at TMI-2.Supporting Documentation & Certificate of Svc Encl
ML20128B674
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/22/1985
From: Aamodt M, Aamodt N
AAMODTS
To:
NRC COMMISSION (OCM)
References
CON-#285-133 CLI-85-08, CLI-85-8, SP, NUDOCS 8505280012
Download: ML20128B674 (66)


Text

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METROPOLITAM P.DISAM CO!*"A'!Y et al. : Dock.ct 50-299S['*2'

             -("hree Mile Island Nuclear                         :

Generating Station, Unit 1)  : STATEMENT OF MARJORIE AND NOR!4AN AAMODT (May 22, 1985) Mr. Chairman, Commissioners, we thank you for this one last opportunity to address this august collegial body. l In the event of a decision and order favorable to licensee, you may be assured that we will challenge that outcome in the outer courts. Although that challenge would be based on several issues we supported in this proceding, today we will simply respond to your order CLI-85-09 which denied our requests for reconsideration and to reopen the record. Your decision was based on your conclusion that we failed to meet the three standards for reopening the record:

1. Timeliness:

You conclude that "The Aamodts have not presented any justification for not requesting...(in June 24, 1984)...a reopening of the record." Our June 1994 motion requested that you, the Commission, verify the elevated cancer death rate and determine whether or not it was related to the TMI-2 accident. You made.:no ittempt

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t6 verify the elevated cancer death rate, although you state in your denial that "the central issue raised by the Aamodts relates {} hohhg9 PDR

r-UNITED STATES OF AM'RICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of  : METROPOLITAN EDISMT CO""ANY et al.  : Docket 50-299 ("hree Mile Island Nuclear  : Generating Station, Unit 1)  : STATEMENT OF MARJORIE AND NORMAN AAMODT (May 22,1985) Mr. Chairman, C'odmissionEEs, we thank you for this one last opportunity to address this august collegial body. In the event of a decision and order favorable to licensee, you may be assured that we will challenge that outcome in the outer courts. Although that challenge would be based on several issues we supported in this proceding, today we will simply respond to your order CLI-85-OR which denied our requests for reconsideration and to reopen the record. Your decision was based on your conclusion that we failed to meet the three standards for reopening the record:

1. Timeliness:

You conclude that "The Aamodts have not presented any justification for not requesting...(in June 24, 1984)...a reopening of the record." Our June 1984 motion gequested that you, the Commission, verify the elevated cancer death rate and determine whether or not it was related to the TMI-2 accident. You made no attempt t6 verify the elevated cancer death rate, although you state in your denial that "the central issue raised by the Aamodts relates 1

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to their allegation that there are elevated levels of cancer in the TMI area." With the help of Judge Sylvia Rambo and the TMI Public Health Fund, we did verify the cancer death rate, obtaining all 20 death certificates. Only then was it appropriate to call for reopening the record. We did, thereby, meet the timeliness standard for reopening the record.

2. Whether Claims Raise A Significant Safety Or Environmental Issue:
                  - We would argue a prima facia case.                           Fven GPU did not oppose our motion on these grounds.
                  - We would also note that the standard rests on the words " RAISE A SIGNIFICANT ... ISSUE", FOT PROVE a significant issue.                  It is, afterall, the purpose of the requested litigation to i

prove or disprove the allegations.

                  - We did, however, provide a showing of evidence which would cause a--reasonable mind to inquire further.            This is all we were required to do.

We met this standard for reopening.

3. There Would Be A Likelihood Of Reaching A Different Result:

! - You conclude that " health effects resulting from the TMI-2 accident are not related to a determination of whether TF.I-l can be safely l i operated today." Clearly, you erred in this i

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  '                                                                                                   conclusion.            You acknowledge in the same paragraph that our allegations concerning licensee's deception and neonatalhypothyrodism were relevant.               Beyond this, the effects of licensee's alleged deception and our allegations that health effects are observed on plume lines far beyond the emergency planning radius on emergency is obvious.              In this regard, we have provided you with an affidavit by Steven Forry, the individual responsible for implementing emergency plans in Newberry Township.                             He says that you do not have assurance that these plans will be implemented.

I will now discuss your dismissal of some of the evidence we cresented.

                                      - Neither you nor any of the parties challenged our evidence of
                                                  - symptoms which occurred among literally hundreds of people, in many cases prior to their knowledge that an accident had occurred, that are most reasonable explained as radiation exposure,
                                                  - radiation induced plant (flora) abnormalities,
                                                  - abnormalities, and
                                                  - a grossly increased cancer death rate among people.
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 -                                                                                                              - You state that we "have not provided information that would lead us to question the (Pa)

Department of Health's conclusions "that the tenfold increase in neonatalhypothyroidism observed in 1979 was not due to the accident. What fact could better discredit this conclusion, absent a hearing, than the quick return to normal levels after 1979?

                                     - You reiterate your confidence in "the findings reached in earlier assessments of radiatio'n                                                                      ,

releases from the TMI-2 accident." You know as well as I that these assessments were made in the absence of crucial data:

                                                  - For the period 4:00 - 7:00 am, March 28, 1979, the charcoal stack filters are missing, the period of most core damage.
                                                  - Offsite TLD's were grossly inadequate to define emissions.

i The makeup tank header leaked directly into the environment throughout the accident.

                                                  - The effect of plume touchdown was never considered.
                                                  - Airborne transuranics were not measured.

Beyond this there has been serious criticism ~ the earlier dose assessments by noteworthy scientists. You are familiar with the work sponsored by the TMI Public IIealth Fund (Jan Beyea).

I have also provided you with a hand written memorandum of Dr. Karl Morgan and an excerpt from a letter from CDP. You are dead wrong in relying on the early dose assessments to prevent hearing the health issue.

                              - You contend that currently there are no elevated levels of hazardous radionuclides offsite on the basis of an " EPA" informal field survey with sophisticated radiation monitoring equipment of sites selected by the Aamodts."
                                      - An EPA official acknowledged that the alpha meter was inadequate to the task.
                                      - Further methodology precluded finding transuranics.
                             - You acknowledge that " Transuranic materials emit alpha radiation and could be another possible source of adverse health effects, but you allege that the cresence of transuranics is not a significant safety issue because "The Staff Sas... concluded that the likelihood of                      __           __

measurable quantities of transuranic material becoming airborne and subsequently being released into the environment is low."

                                      - In 1980, TMI personnel provided an aerosol sample taken from the TMI-2 auxiliary building to the Inhalation Toxology Research Institute, Lovelace

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 .                                                                                                                                                                                                         Biomedical & Environment Research Institute for analysis. They found that as late as 1980, there were still measurable quantities of plutonium, americium and californium in the air of auxiliary building.
                                                                                                  'de have a witness who will testify that licensee did not measure, inplant, for transuranics, - Randy Thompson.   (Affidavits attached.)'
                                                                                               - Transuranics, as released, could indeed be expected to cause serious health effects.

This will be discussed by Dr. Carl Johnson. You conclude that our allegation that licensee deceived the Pennsylvania Bureau of Radiation Protection concerning radiation measurements following a known releast at about 7:00 am March 23, 1979 over the area we studied was unfounded. You based this conclusion on the staff's response to our motion. The staff discredited our allegation on the basis of a telephone call which was alleged by your investigators to have been made by Mr. Gerusky I at 9:00 am to PEMA, wherein he allegedly stated that at that time he had been informed of survey measurements at Goldsboro.

                                                                                             - The PEMA log has no such 9:00 am entry.
    . - - _ __ _ _ _ ... _ _..,_ __ _ ___ _.__.~. _ ___.._... _ . _ . . _ . . . _ . _ . _ . _ ~ -

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   >-                                                                                                     - The facts are just as Mr. Gerusky stated them on May 29, 1979:                                                                           He held on the line while he waited for a non-existent survey team to report a non-existent radiation reading.which discounted the presence of the plume which we allege caused the sevenfold elevation of cancer deaths in its path.

You have a mandate to assure the protection of the health of residents around operating nuclear power plants. We have informed you of-the likelihood that there is a population at risk at TMI. Because of our close personal , involvement with many of these people and their reliance on us to prevail on their behalf, you may he assured that, should you fail to promptly take actions appropriate to their risk and your legal mandate, we will take every appropriate step to have this commission charged with malfeasance. i We would note in closing that the MRC staff has on at least four occasions denied public access to our motions relating to health effects. We have written to Thomas R. Combs of your staff on Apri'. 26, 1985 and request an expeditious explanation of the denial of our motions to the public. One request we reference is that of Dr. Andrew Baum, Uniform Services University, Bethesda, Md. who has investigated psychological stress in the "MI area. Dr. Baum's office was informed that the NRC was unaware of the Aamodts or a motion. 1

       >                                    DOCUMENTS REFERENCED BY STATEMENT OF MARJORIE AND NORMAN AAMODT May 22, 1985 Before the Commission Commission Order CLI-85-08              (throughout)

Testimony of Steven Forry, Deputy Emergency Management Director for Newbury Township at the Suffolk County Legislature, New York, March 27, 1985 (paga 3) Handwritten Memorandum of Karl Z. Morgan, former director of Oak Ridge Laboratories, presently director of the TMI Public Health Fund, " Missing and Inadequate Data on Radionuclides Peleases and Population _ Doses.Resulting from TMI-2 Accident of March 28, 1979" (page 5) Letter of January 7, 1985 from Centers for Disease Control (Dr. Glyn G. Caldwell) to Dr. Bruce Molholt (page 5) Characterization Of An Aerosol Samole From Three Mile Island Reactor Auxiliary Building, G.M. Kanapilly et al., Inhalation Toxicology Research Institute, Lovelace Biomedical and Environmental Research Institute, P.O. Box 5890, Albuquerque, NM 87115, January 1981, Prepared for DOM (page 5,6) Affidavits of Randall and Joy Thompson. (page 6) Statement of Carl J. Johnson, M.D.,M.P.H. (page 6) Letter of April 26, 1985, Marjorie M. Aamodt to Thomas R. Combs, Chief, Correspondence & Pecords Branch, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 ~ with attachments (three requests and MRC responses) (page 7) t f d 7 er." M 7;: \ , Le,. ,%. w

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         .'                               UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of                                      :
              !!ETROPOLITAN EDISON COMPANY et al                    :   Docket 50'SpyJI (Three Mile Island Nuclear                          :

Generating Station, Unit 1)  : 2 MAY 23 PS:32 GFFh e- iL: ~t A-CERTIFICATE OF SERVICE 00CXEig& E?Vl1 This is to certify that the STATEMFNT OF M.ARJORIE AND MOR'iAN AAMODT and referenced documents has been served on the Commission, Boardsfand parties to the proceeding. / - l $4LLfML . Wu

                                                      ' Marjotie M. Aamodt May 23, 1985 l

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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
                                                                                                                                  - ;} -

COP 9tISSIONERS: Nunzio J. Palladino, Chairman Thomas M. Roberts 3 gy g P3,02

,                    James K. Asselstine l                     Frederick M. Bernthal                                                                                   I -

Lando W. Zech, Jr.

                                                         .                            ..                                    '"' {.l-Q:y l

In the Matter of

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METROPOLITAN EDISON COMPANY Docket No. 50-289 (Restart) ( (Three Mile Island Nuclear Station, Unit No.1) 7

                                                                                                                     $ERVCD DAY lb 13@3 l

MEMORANDUM AND ORDER CLI-85-08 l l

I. Background and Sumary l

On June 21,1984, Marjorie and Nonnan Aamodt filed a motion with the Comission alleging that releases of airborne radioactive materials from the l March 28,1979 accident at TMI-2 were substantially greater than have been ) acknowledged and that these releases have lead to an unexpectedly high level of cancer in local residents. The Aamodts based their allegations on 5 door-to-door interviews that Marjorie Aamodt and others conducted of  ! residents of two areas near the TMI-2 facility. The Aamodts requested the [ i Comission to investigate their allegations and to defer a decision on the l restart of TMI-1 until the issues they raised had been studied further and fully resolved. On December 13, 1984 the Comission denied the Aamodts' i motion to sponsor a new study of health-related issues arising from the TMI-2

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Z P accident. The Comission stated that the "Aamodts had not presented 1 sufficient reliable information to show that previous, more comprehensive and J scientific surveys of TMI-2 accident radiation releases are erroneous." CLI-84-22, 20 NRC 1573.1 , l On January 15, 1985 the Aamodts filed a motion asking the Commission to reconsider the December 13 denial of their request. They also requested the Commission to reopen the record in the TMI-l restart proceeding, asserting , , that the issues raised by their survey were relevant to "the management competence, emergency planning and health issues" litiga';ed in the restart proceeding. On April 13, 1985, the Aamodts amended their request by submitting additional information. For the reasons which follow, the motions to reopen the record and to defer a decision on TMI-1 restart are denied.2 II. Analysis of Motion to Reopen the Record The Aamodts claim that the record of the restart proceeding should be reopened to examine health-related issues ari' sing from the TMI-2 accident. The Aamodts allege that death certificates obtained from the Pennsylvania 1 Comissioners Asselstine and Bernthal dissented. They would have provided NRC funding to ongoing studies being conducted by the Comonwealth of P.ennsylvania's Department of Health. 2 Should the Comission in the fur:re acquire information regarding the need for any further studies along the lines requested by the Aamodts, it will, of course, make its views known along with any appropriate recomendations. The NRC staff is currently evaluating this matter and will be providing recommendations to the Comission shortly. The Comission is also assessing whether the Commission's Advisory Panel for the Decontamination of TMI-2 could provide a useful forum for citizens to raise health-related concerns. These matters are not relevant to the restart proceeding because health effects resulting from the TMI-2 accident are not related to a determination whether TMI-1 can be safely operated today. See II.C, infra. .

      ~

3 i Department of Health establish that: (1) there is an elevated cancer mortality rate in certain areas surrounding TMI-2; (2) an increased rate of neonatal hypothyroidism in Lancaster County in 1979 resulted from the TMI-2 accident; (3) sericus post-accident health effects within and beyond the ten- ,

          . nile radius of TMI demonstrates the presently-approved emergancy plans are inadequate; (4) residents near TMI are suffering adverse health effects from high levels of radiation currently in the environment; and (5) the 5100 j          degree Fahrenheit temperatures reached within the TMI-2 core during the accident produced elevated levels of fission products and transuranics which have escaped to the environment and could be harmful to the public.

The Aamodts also believe the record shoul.d be reopened on an issue relating to the integrity of licensee's management. The Aamodts allege that information developed in the restart proceeding on the Dieckamp mailgram issue demonstrates that licensee personnel lied to the Pennsylvania Bureau of Radiation Protection on the morning of March 28, 1979. The Aamodts maintain that after the Comonwealth had been warned of projected radiation releases of ten (10) rems per hour over Goldsboro," TMI personnel discounted this information by claiming, contrary to fact, that the surveillance teams had been dispatched and had. verified that a significant release had not occurred. Under established Comission practice three factors are considered in determining whether a motion to reopen should be granted: "(1) Is the motion timely; (2) does it address significant safety (or environmental) issues; and (3) might a different result have been reached had the newly preferred material been considered initially." In the Matter of Metropolitan Edison (Three Mile Island Nuclear Station, Unit No.1), CLI-85-2, 21 NRC 282, 285, n.3(1985).

4 r The NRC staff opposed the request to reopen the record, arguing that the criteria for reopening the record had not been satisfied. The licensee also opposed reopening of the record on whether licensee personnel lied to Bureau of Radiation Protection, but did not take a position on whether the record should be reopened on the other issues raised by the Aamodts. A. Timeliness The central issue raised by the Aamodts relates to their allegation that there are elevated levels of cancer in the TMI area. Their request to reopen the record on that matter is untimely. The Aamodts first presented their concerns regarding cancer levels to the Commission in June of 1984, yet did not request reopening of the record until January of 1985. The Aamodts have not presented a'ny justification for not requesting at that time a reopening of the record.3 B. Whether Claims Raise a Significant Safety or Environmental Issue The Commission has reviewed the material presented by the Aamodts regarding alleged elevated cancer levels in the TMI area and continues to l

   .believe that the prior studies are correct in concluding that the number of l

health effects from radiation releases arising from the TMI-2 accident will be negligible ~. The Aamodts have not presented information which casts doubt on the previous stud'ies. For. example, the Aamodts have not reported when the I cancers which fom the basis for their allegations were diagnosed relative to 1 l t 3The Aamodts also have not established when the information they rely on in support of their other claims became available and whether the facts could have been presented to the Comission at an earlier date.

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the TMI-2 accident and have not shown that the cancers resulted from the i TMI-2 accident. When the cancers arose or were first diagnosed is particularly significant, in light of the obvious fact that cancers which ) arose prior to the TMI-2 accident cannot be attributed to the accident, and the fact that, even for those cancers arising since the accident, the undisputed scientific evidence is that there is generally a latency period > for cancer development following exposure to radiation. Even if additional 4 information, such as date of diagnosis of the cancers, type of cancer, health, occupational, and personal histories of the deceased were available, we believe it is unlikely that statistically and scientifically valid conclusions could be reached regarding the causes of the cancers in the small population groups associated with the Aamodts' informal survey. The epidemiological evidence presented by the Aamodts is fragmentary and anecdotal. As a technical and logical matter, it is not sufficient to support a reasonable doubt as to the adequacy and correctness of the several detailed scientifically conducted studies on which the Comission relied. ' Therefore, under the circumstances, the Aamodts have not raised a significant safety or environmental concern. Their other claims similarly fail to raise significaat issues. With I respect to their allegations that there was a higher rate of neonatal l 1 hypothyroidism in Lancaster County in 1979 than there was in the 1981-1983. I period, the Pennsylvania Department of Health has analyzed the seven cases of hypothyroidism that arose in 1979 and concluded that they could not be attributed to radiation, but should be attributed instead to factors such as 1 incomplete maturation of thyroid glands and lack of enzymes to synthesize thyroxine. In fact one of the seven cases occurred prior to the accident and another within three months following the accident, a time period too short t

6 V for the hypothyroidism to have resulted from the TMI-2 accident. The Aamodts have not provided information that would lead us to question the Department of Health's conclusions' . The Aamodts' allegation that health effects reported by TMI area residents, such as nausea and severe vomiting, resulted from radiation released from the TMI-2 accident that was higher than reported is not supported by available information. The NRC staff estimates that the average radiation dose to an individual within ten miles of the TMI site resulting from the TMI-2 accident was approximately 8 millirems, and the average dose received by individuals within 50 miles was approximately 2 millirems. Based i on accepted scientific principles governing the effects of exposure to varying levels of radiation, these dose levels are far too low to be the cause of the kind of adverse health effects cited by the Aamodts. In the

 -          absence of other evidence demonstrating a link between the cited health effects and the TMI-2 accident, the Comission must continue to support th~e findings reached in earlier assessments of radiation releases from the TMI-2 accident.

With respect to the Aamodts' claim that there are currently unacceptably i high levels of radiation.in the environment near TMI, the NRC staff, the s Environmental Protection Agency and the Pennsylvania Department of Environmental Resources conducted an informal field survey with sophisticated

        ,    radiation monitoring equipment of sites selected by the Aamodts. The i             agencies concluded that the radiation levels were within the normal range.

The Aamodts also speculate that the high temperatures (in excess of 5000 degrees Fahrenheit) reached within the TMI-2 reactor core during the accident created a "high probability" that transuranic materials were released into the atmosphere. Transuranic materials emit alpha radiation and could be

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        .another possible source of adverse health effects.                                                  The NRC staff has     j examined these allegations and concluded tnat the likelihood of measurable quantities of transuranic material becoming airborne and subsequent.ly being released into the environment is low. .The staff further noted that no measurable quantity of transuranic material other than that associated with normal background levels has been identified in any of the air or soil samples taken around the TMI site during or after the accident. Accordingly, again the Aamodts concerns do not raise a significant issue.

Finally, the Aamodts' claim that the licensee deceived the Pennsylvania Bureau of Radiation Protection concerning radiation measurements on the day of the TMI-2 accident is based on a draft document which was prepared in the

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courseofanNRCinvistigationconductedin1980,butbeforepertinent i individuals had been interviewed by the NRC. After the interviews, the staff determined that the facts contained in the working draft were erroneous and concluded that the licensee had not provided erroneous information relating to the Goldsboro dose-rate prediction. The Commission has concluded on the basis of its review of the allegations and the staff's and licensee's responses that 'the Aamodts' claim of deception is not supported'and accordingly does not raise a significant safety issue. ' C. Likelihood of Reaching a Different Result The Commission does not believe that the information presented by the Aamodts in their motion would have led to a different result. With the possible ex.ception of the claim that Metropolitan Edison Company officials deceived Commonwealth officials on TMI-2 accident radiation releases and the l i i 4

1 [ l i neonatal hypothyroidism issue,4 the Aamodts' concerns are,not relevant to the restart proceeding because health effects resulting from the TMI-2 accident are not related to a detennination whether TMI-1 can be safely operated j l i today. As discussed above, the Commission finds that the Aamodts' claims of l licensee deception to be without any foundation. With respect to the i neonatal hypothyroidism, the information presented by the Aamodts does not form a basis for concluding that the Licensing Board erred in LBP-81-59,14 NRC 1211, 1596 when it concluded that the alleged increased in neonatal hypothyroidism was not caused by the TMI-2 accident. For these reasons the Aamodts' motion to reopen the record is denied, as well as its request that the Commission sponsor a health effects study prior to making a restart decision. Commissioner Asselstine's separate views are attached. It is so ORDERED. . [ggRREcpDo Fo the Comi ion

                                                          -s P.                       /-

y . g g (( ,..h/U.A.~- g SAMUEL J. CsiJb4 s 4 '.~ %

                                          ,)o* yO> ',,? r,,_,-
                                                          * ., 5: Secretary off the Commission k' vq-    '
                                                      ^'

Dated at Washington, D.C. o r this /6 .bday of ht.w-, 1985. N * *

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i khe Licensing Board addressed the hypothyroidism issue in the context of evaluating the protective action criteria used by the Commonwealth of Pennsylvania in emergency planning. S ce=niasioner Boberts was not present for the affirmation of this ite, 4 if he had been present, he would have approved.

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  • AT rwt suPFa a.K (age \$1 AkuR.C j 7g M A R.c H T1,\SP5-1 people who was in our survey area who lost her husband could 2 tell you what this meant to her, and her own experience.

3 MR. BLASS: So we are going to Steve now? 4 MRS. AAMODT: Steve Forry. 5 MR. BLASS: If he could trade places with you, 6- please. 7 Would you remain standing and raise your right 8 hand.

           . 9                (Whereupon, Mr. Steve Forry was sworn by Mr.

10 Blass.) 11 Please be seated and state your name and address 12 and occupation, and begin your statement. . 13 MR. FORRY: My name is Steven Forry. I am a full 14 time staff paramedic at York Hospital in York. I am also 15 the Deputy Emergency Management Director for Newbury 16 Township in York County, Pennsylvania, which is directly 17 across from Three Mile Island. 18 First of all, I would like to thank you gentlemen 19 that invited us up here today to share our concerns with N you all. 21 To give you a little personal background -- I am 22 going to make this as brief as I possibly can. When the 23 Three Mile Island nuclear power station was going around 24 and having the interviews, and just letting you know what 25 they were planning on doing, I wasn't the least bit concerned

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.'+ 1 about nuclear power. It was a new technology. The  ! 2 Government had assured us that it was safe. There were so I - 3 nany safeguards built into these plants that _they would be 4 able to detect an accident before any harm could come, and 5 the bottom line was that it was most economical. That 6 our electric bills would be cut in half. 1 7- And unfortunately -- Murphy's Law says anything 8 that can happen will, and it did. We have seen double 8 in our electric bills back home, and we have seen an 10 accident at Three Mile Island that nobody has ever seen 11 before, i 12 At that particular point in time I had ten years i '- 13 involvement in the Newbury Town fire company as many . 14 different officers, and when the accident occurred we 15 discovered that we did not have a workable plan for 16 evacuation at the time of the accident. 17 There was a quick couple of meetings put together 18 where some ideas were put down on paper so that when they 18 did call for a general emergency that we could be able to 88 evacuate, and I quote, as many people as quickly as possible. 21 So, once the plan was as best formulated as could l 8 be, the next couple of days were pretty hectic. A lot of i 23 ~ things were going on that we were scared about. We had a l 24 mass exodus out of our community of about at that time ten f l l L

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  • 1 to eleven thousand people. We had people ' that lef t their y

2 homes and took as many of their belongings with them as they 3 could. Actually left their homes unlocked, and it was up 4 to the people that were left behind to patrol these areas 5 and see if there is anything possible we can do to at least 6 keep down on the looting. There were some national guard 7 called out to close some of the roads down. We don't have 8- to worry about that. 9 And we learned from that experience very greatly 10 that we were not prepared at all, in any way, shape, or 11 form to evacuate any of the people except those who were 12 able to get in their automobiles and get out of there before e 13 the mad rush. 14 As Margie touched on the health study, what got 15 me involved in this even more deeper than the emergency 16 planning is the fact that within a mile radius of my home

17 we had thirteen to fifteen people die of cancer within a 18 two to two and a half -- two to three year period after the l

l l 19 TMI incident, and only because I have run ambulance for the

               #     last ten years, and now for the last fif teen, I took notice

[ 21 of the enormous amount of people that we were transporting 22 l for different treatment for their cancer. 23

i. I started to see husband and wives dying of cancer 24 in the same household, all within this same two to three year 25 period.

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81 1 And that is why I started being really involved ( 2 in better planning'for our township. 3 In September of 1980, 1 took the position of 4 Emergency Management Director with Fred Sanders as my 5 deputy, and we changed places every once in a while because 6 of time and our college that we are both working on. At 7 the present time I am the Deputy, and Fred is the Director. 8 May I say to you gentlemen that I was appalled 9 on the way up here yesterday, being from a little community 10 that I am from, of the traffic which you folks have to bear 11 every day, and my heart goes out to you. 12 I got to the hotel and the first thing I said to e 13 the person was: Is there a convention someplace up yonder k 14 here? And she said: No. I said: Where are all these 15 people going? And she said: Oh, this is just normal 16 traffic. Don' t go out there in about two hours, you won't 17 go anywhere. 18 And when I looked out my window I just could not . 19 believe it. I am not used to it, so this of course is like 20 a mountain to me. 21 And I thought of the fact of having to evacuate, 22 and it just scared the pants right off of me. I am serious. 23 I knew what it was back in the little metropolis of Newbury 24 Town, and we are talking thirteen thousand people where I 25 live now, with all the people that wn have to have from

82

  .          1    Go1*dsboro, from -- that have to come into our township to

(- 2 hit the main arteries to get out, and I .think of now three ( 3 million some odd people coming down 495. It just really 4 scares me to think think if there would have to be a mass 5 exodus of the problems that you folks are all entailed to 6 accomplish that goal, t 7 The naivety of me believing in our Government -- and s I still do -- there are problems, of course, in any part 9 of Government, any part of personal life, but I found that to maybe I was a little too naive, in that I started looking 11 at a plan that we had a little more prospectively. And I 12 found that our plan calls for eleven school buses to be , 13 used to transport the people that don't have transportation. 14 These might be bedridden people, these might be people that 15 cannot walk, people that just don't have any friends, or 16 people to take them. 17 So, it is all in our plan that we had eleven buses 18 guaranteed, set aside for use during an evacuation of 19 Three Mile Island. - 20 And I asked a very simple question one day at 21 a meeting, and the question was this: In addition to the 22 buses, do we have any drivers for these buses? U And the answer was, no. 24 Ne have two hospitals in the 20 mile radius of M Three Mile Island in our area that we would be responsible

    .     .                       I                                                                                                                      83 1        for, and it has on there that wa have an additional 25 2        ' ambulances coming in to transport people, l(                             -

3 I asked again: Do we have drivers for these 4 vehicles? 5 And the answer again was, no. 6 And I want to ask you gentlemen,as prudent human 7 beings, if you got a call from anybody, me, and said look, 8 we have a mass problem here. We are evacuating our area 9 due~to an immediate danger at Three Mile Island. All of to our people are leaving. Would you drive some buses up into 11 our area and pick up some of our people?

            .              12                               That is what it boils down to.                                       I testified before
 ~,                        13         the Nuclear Regulatory Commission about two or three years

( 14 ago, and the gentlemen started off by asking one question. 15 lie said: Mr. Forry, in the case of an all out evacuation, 16 what would be your first priority? 17 And as I stated in the beginning, this is a 18 volunteer position in our township, and it is no excuse for i 18 not doing;your job right. I am just saying that if that 2 should happen, my first priority in my life is my wife and 21 my two children and my f amily. And that would be my first 22 priority, to get them out of that area, immediate danger,

                           #          and then if there be anything possible                                                  to do, that I would 24 try to do that.
  ^
                           #                                But seeing as though Route 83, the main artery that I

A

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84 h . g I we are to take is only two lanes south and two lansa north, all the traf fic flows are supposed to be diverted south. ( 2 3 Okay, both north and southbound lanes. 4 The potassium iodide that we are supposed to get 5 for protection has to come up that route, with all the 6 people heading towards them. It would not be able to get 7 to us unless they flew it in. 9 We are supposed to have X' amount of State Police 9 that takes care of major traffic points. In talking with to the police, and this I did on my own -- I just went to those 11 people that we have on our list that makes this plan look 12 so well -- and I said: I want to ask you. If you are on 13 duty, or not on duty, and you get a call and say they are C 14 evacuating the area, there is an immediate danger, would 15 you come? 16 Their answer was, no. 17 And I cannot hate then for being honest with me 18 in saying that if there is an all out danger that you 19 folks have to get out of there, who is going to come and i 3) take our places in that danger zone? And it would be just 21 about each for himself, okay? 22 The main thing I want to get across to you is that 23 of your plan. I have not had a chance to look over your 24 plan. I am not saying that I am a professional at it. 25 All I am saying is that in my six years of continuing to

85

     ._,.              I'          work .with this plan, and trying to make it better, we 1                   2 realize more and more that there would be lives lost and 3

there would be more chao's in evacuation itself than we would 4 be able to handle. .The little eight people on our Committee 5 would not be able to control thirteen thousand people coming 6 at us, and in no way, shape or form be able to direct them 7 in the right area. - _ ,, 8 The main thing is -- I have two children. One 9 goes to middle school up in New Cumberland, .which is north. 10 My other child goes to Newbury. We are supposed to head 11 south. If anybody in their right mind thinks I am going to

              -     12 let my little girl behind, they.are crazy.                     And that is 13            what everybody -- every adult that I have interviewed in 14 our township states that they have their priorities, and 15 that is to get their family together and get out of there 16            as quickly as possible.

17 So, I am asking you gentlemen, in all of your 18

                                 . consideration, in all your honesty as public cit'zens,               i   as 19 public protectors, to look.at your plan.
                                                              ~

20 ! MR.' PROSPECT: We have already concluded that it 21 can't be done. 22 MR. FORRY: That is what I am saying. And that 1 23 is what my basis-is, that it is almost next to impossible 24 to evacuate this many people in such a short time. 3 During the accident at Three Mile Island, I was

                ._        .__ __      _ _ _       _.. , _ - _   - . _ _ . ._ ~ ,     . _ _ _ . _    _ _   . _  .- . .    . . _ .

86

  ~...          I    appalled to see people fist fighting over gas pumps, j;           2     because some of the gas stations closed. And there was no 3     all-out evacuation.

4 It was folks, if you would feel more comfortable 5 leaving the area a while, if you have some place to go, 6 throw a couple of belongings in a vehicle and go. 7 And I mean to tell you, it was just utter chaos.

             '8     We had to pull the ambulance into one place and just break 9    up fights because people were fighting over gas pumps.

10 To get gas to get out of there. And these are the kind of 11 things that we have to realize. That people and their

       *  . 12     personal feelings, how they react to situations. It is
 , q         13     going to be just barbaric.

14 One other final thing. We have tow trucks and 15 bulldozers' in our plan' to help disobstruct traffic. I 16 went to the tow truck operators and I asked them the same 17 question. Guess what their tow truck is going to do? 18 Their tow truck is going to be sitting right 19 underneath them, and they are going to be pushing cars out 20 of the way to get out of here. 21 And that is being honest. I am telling you, this H stuff all looks nice on paper, but it is really scary to 23 think if they would have to get these people out of here. 24 Thank you for your time and your patience. 'l

 \-         25                            (Applause.)

4 87 1 MR. BLASS: Thank you very much. Mrs. Aamodt, 2 did you want to say something? 3 MRS. AAMODT: Steve stayed. His wife stayed. 4 .She fed the emergency workers. IIis wife is not well from 5 having'done that. 6 The people in the area will not take any reassurance s 7 that everything is all right again. They have looked around. 8 They have counted seven, ten, eleven people have died of 9 cancer, from their window. They can see this. And they 10 have come to the conclusion that they are not going to stay 11 again, no matter what the recommendations are. I think that 12 is pretty much -- they don't believe any recommendations. 13 They will just know there is a problem, and they will go. 14 MR. BLASS: Thank you. We have time maybe for 15 two more speakers, and then we lose our reservation for 16 this facility, so I will leave it to you -- I know Mary 17 Osborn -- 18 MRS. AAMODT: Mary has a very important presentation, 19 Jackie was one of our people in our study. I think if she ' ~~ just took a minute and just stayed directly to that rather 21 than reading from the statement that she had. Jackie is 22 right here. 23 tm. BLASS: Ma'am, would you please remain standing 24 and raise your right hand? 25

gg

 ].    .
           ,1             (Whorcupon, Mrs . Brockman was sworn by Mr.

2 ~Blass.) 3 Please be seated, and state your name and your 4 address and your occupation, and you may begin your 5 statement. 6 MRS. BROCKMAN: My name is Jackie Brockman. I 7 live right outside Newbury Town. And I am a homemaker 8 and secretary. And I am here not as an expert witness, 9 but just as representative of your average person who went to through this experience and can tell you briefly how that 11 experience impacted our family.

                              ~

12 I have it written out, and I have never spoken

   -      13   in the public. If you will bear with me for just a few k-      14  minutes.

15 We lived in the area at the time of the accident. 16 My fiance lived five miles approximately -- I lived 17 approximately five miles from the towers. My fiance lived 18 within three miles from the towers. 19 Wednesday wo were not aware that anything was 20 going on. Uc did not hear anything about the Island. Any 21 problems on the Island. Thursday, when I went to work, my 22 employer said: I didn't think you would be here. 23 And I said why? They said, well there is a problem 24 down there. I said well, it must not be big, or they would l M have told us. He lived there. I trusted them to tell us I i r

_t . 39 3- 1 if there was a problem. J[ 2 So, I went back home and stayed there. 3 ~ Friday morning, when we had the big problem, I 4 got my daughter up. She stood outside waiting for the s . school bus' that morning. She went to school. Mid-morning 6 the. sirens started. I turned on the radio, they were 7- advising pregnant women and five year old children to leave a the area. 9 I am supposed to be factual. It is a fact thct to that is a stomach churning, knee-shaking fear that you get 11 in a time'like that. I threw things'in the car that I 12 didn't want to leave behind. I tried to use the phone. 13 - You can't use your phone at a time like that. The phone .C 14 doesn't work. The lines are busy. You can't get through-15 at all. 16 I started over to meet my fiance to tell.him'I 17 was going to get my daughter. He was coming over to meet 18 - me. So we. met in the road halfway there. He went up to 19 Lemoyne, about nino miles north. I went down, signed.a 20 release to get my daughter out of school, along with 21 numerous other parents, and we evacuated at that time. We M moved about ten miles north. M I stayed there for the whole week following the 24 accident. My daughter stayed there the whole time. She 26 did not go back any closer than ten miles.

<a -

90

  • 1 My fiance and I went down every day to check his

( 2 3 business and our homes, and various things like that. were down'every day. We We spent time outside checking things 4 out. 5 The day, Friday, of the accident, there was a 6 strong metallic taste. It tasted like you would put an 7' old copper penny on your tongue. And subsequent days 8 when we were outside checking things in the area, we again 9 tasted that metallic taste. We tasted that subsequent to times in the next three, four years when we went outside, 11 when they were reporting releases you could taste that, 12 and some days when they were not reporting emissions you 13 . could taste that. 14 My fiance was in good health until the Summer of 15 1980 when he began tiring early, catching long heavy colds 16 and chest congestion, and having back pains. Ile went to 17 see several practitioners over the summer and fall. They 18 diagnosed flu, cold, things like that. The symptoms got 19 worse, lie had a subnormal temperature for several months. 20 He had savore night sweats. IIis back pain got worse. He 21 had cracking and bleeding on his fingers and around his 22 moutlt . He had small hemorrhages under the skin inside his 23 mouth. 24 As the fall progressed, he was not able to walk 25 without a cane at times. I{is back pain was that severe.

91

 .i                                                                              !
                                                                   }        .
   ,        t              Thcy said ho pulled a mu2clo, but it got gradually

( 2 worse, and none of the treatments did anything. In January, 3 he was rarely out of bed. He got an attack so severe in

         .4      January of 1981, that they took him to the hospital in the 5     ambulance. The same weekend, they took two neighbors who 6     live within half a milo or less to the hospital. Their 7     diagnosis was the same as his; cancer, a              The doctor, the cancer specialist who took care of 9    him diagnosed multiple myeloma, which he explained to me to    as a bone cancer involving the bone marrow which manufactures 11     blood cells. He received chemical    chemotherapy and radiation 12     which gave him some remission that summer.

13 We were married in the following spring. Then 14 ho got worse again. He suffered severe and crippling 15 pain. He was not able to work in his business. He had to to make a heartbreaking decision to close his business which 17 he had built up himself. As the disease progressed, the 18 leukemia grew in severity, as did the pain and crippling, , 19 necessitating the use of a TZ::S unit, which is transtaneous 20 electrical nerve stimulation, with strong narcotics for 21 pain. He also had to go to the hospital for sassions on 22 a machine that cleansed his blood of the abnormalitics in 23 the blood, and blood transfusions. He progressed from 24 use of a cane to the wheelchair to being bedridden. l He l 25 died one year and ton months after the diagnosis. l l [

92

    ,            1               Ha was 51 years of aga.

( 2 During that time, and since then, my daughter who 3 was twelve at the time of the accident has suffered severe 4 sinus attacks, headaches, frequent sore throats, bouts with 5 ' nausea'for days at a time. She sleeps long hours; twelve a to fourteen hours at a time, and she is always tire'd. 7 She hascondy1'e Oba.dr.1malesia, which is a painful 8 softening of-the kneecaps and joints. She has several 9 friends in our church and in her school who suffer from

            - 10      this same thing. And sclerosis. Both are bone problems.

11 And she had none of these problems, or any sign of them 12 previous to the accident. She has been tested three times 13 in the last year for mononucleosis, with negative results. C. 14 And the doctor's have not been able to find a cause or a 15 diagnosis for these symptoms. 16 However, they -- especially the joint problens -- 17 limit her range of activity and her future range of job la possibilities, since she cannot work or stand-for long 18

                     -periods ^due to joint pain.

so I must conclude this by stating that the impact 21 of Three Mile Island and the accident there on the lives 22 of my family and myself, has been overwhelming. Medical 23 expenses that are high, loss of the business, loss of 24 something more precious, our health, and the most precious

 \          28 gift of all, a beloved human life.

I

93 l

   ,     t.               That is all I have~to say.

( 2 (Applause.) 3 MRS. AAMODT: That is the story of the people. 4 That summarizes it. So many -- the business of the knee - 5 caps of the children, I didn't even know that until now. 6 It is reminiscent of what happened to the animals. They 7 couldn't stand up. They staggered and fell down. And 8 was right after the accident. And that was dismissed 9 as a selenium deficiency. , 10 MR. BLASS: Thank you very much. We'have time 11 for one more speaker. Whom would you suggest? 12 MRS. AAMODT: I believe Mary has prepared some 13 work on the flora abnormalities that you might be interested 14 in hearing. 15 MR. BLASS: We would like to wind up by maybe 16 two o' clock or shortly thereafter. 17 So, if you will remain standing and raise your 18 right hand, please? - 18 (Whereupon, Mary Osborn was sworn by Mr. 20 Blass.)

           ~

21 Please be seated. State your name, address, and 22 occupation for the record, and begin your statement. 23 MS. OSBORN: Mary Osborn, Swatara Township. I am 24 a housewife. 25 First, I want to comment on something he said 2 f), f I O!- f_ . Cw  ? 79 1

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   -                                                    to Dr. Bruce Molholt,(see under Aamodt FOIA request)page 2) , provided
                                                                                                                                                                                                         .lanuary 7, 1985 i

mmIEEEEEEleummmu trol over the Nucleur the Aamodt Study. Upon In reply to ynur December il letter, I have no conaboutabout our review Regulatory Commission's statementsletter d the (copy enclosed), I agree itinterpre reviewing ey the data collection, the analysis, anI still have those reservations. Aamodt report. With regard to your first point, I have no information about Thone data were nnt in the reconfirrsa Vere cancer deaths after completion of the how were study.the cancer deaths reconfirmed? report. The question remains if the cancers were proven by rissue The THI

     '                 medical                    records reviewed                                               Three Mile Island (TNI) Accident?if the canc fte to ascertain examination and diagnosed a_f,t,er,the                                                                                                                                                   d afterwards.

Accident cannot be blamed as the cause of a cancereven the thour,h t before the 1HI Accident, and date of diagnnets F.ven if some of the cancer cases were diagnose ident t theories of human concer relatively brief latent period longer average latent between period. the acc(lese then development that assume a (60%) the h has reviewed 12 of 20 death certificateswee diagnosed with Fven though had, important data item is when the patient the pacient died. Also, 8 (401) of the 20 concer deaths have noti w of according to your letter, even a rev e dical records, then this= if all the deaths were confirswd by me I do agree that increas_e. would be e statistically significant PennaylVAnia State I)epartment of We have continued to collaborare with thelikely exposed popuistions l in inquiring (within Health to follow-up the nostWe collaborated on a census of this popu at ocedica around the THI site. in the area, past about evacuation, time opent of llealth has continued this follow-up. history. The State Departnant

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Page 2 - Dr. Mruce Holholt J Finally, suspicions of an increased frequency of disease should be reported to the Stata Department of Health for their evaluation investigate since such by law they evapicions whenare the respo,ethle. CDC will help the State State requests it. Sincerely yours, Clyn G. Caldwell. H.D. Assistant Director for Epidemiology Chronic Disemees Division Center for Environmental Health - Enclosure ces Dr. Zack Dr. Tokukata Dr. Hills

                  .CDC:CEH:CDDICCaldwe11:dk:1/2/85: Doc. 6080D i

e e D 9 e

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9__-___________________

   ,     ,    -                                                                                           LMF-70 Category: UC-48 CHARACTERIZATION OF AN AEROSOL SAMPLE FROM THREE MILE !$LANJ REACTOR AUXILIARY BUILDING G. M. Kanapilly J. A. Stanley G. J. Newton                                            '.

B. A. Wong P. 8. DeNee i ' Inhalation Toxicology Research Institute - Lovelace Biomedical and Environmental Research Institute P. O. Box 5890 Albuquerque, NM 87115 January 1981 Prepared for the Office of the Assistant Secretary for the Environment of the United States

                    -             Department of Energy under Contract Number DE.AC04 76EV01013.                  ,

I

! i p3g, i l ACENOWLEDGMENT ............................................................................ 1 f ExtCUT IV E SUMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 INTRODUCTION .............................................................................. 2 MATERIALS AND METH005 ..................................................................... 2 i Aerosol $asple ....................................................................... 2 l Dissolution .......................................................................... '3 Analysis of Dissolved Activity ....................................................... 3 Detemi na tion of Gamma Acti vi ties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . > 3 Scanning El ectron Mi cros copy inergy Di spers i ve X Ray Analysi s . . . . . . . . . . . . . . . . . . . . . . . . 4 Al pha Spect ros copy . . . . . . . . . . . . . . . . . . . 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 RESULTS ................................................................................... 7 0!$CUS$10N ................................................................................ 9 REFERENCES ................................................................................ LI$f 0F TA8tts 2 Table 1. Radionuclide Activity (nci) in the TMI Filter Samples as of 79305 .............. Table 2. Elemental Composition of the TMt Aerosol $4sple as Determined 6 by Energy Dispersive X-Ray Analysis ............................................ F LIST OF FIGURES

                                                                                                                                                                            .PJ19.

3 Figure 1. A schematic of the flow through dis solution sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Figure 2. Game spectrum of Segment 1 of the TM1 aerosol as determined 4 i n a coa xi a l Go- Li de tec tor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Figure 3. Dissolution of radionuclides in a flow-through system expressed as fraction 5 di ssolved versus el apsed time (hours ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Figure 4. Dissolution of radionuclides in a static system expressed as fraction 5 di ssolved versus el apsed time (hours ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Figure 5. Scanning electron micrographs of original aerosol sample from Segment 3 ........

            *:gure 6. Scanning electron micrograph of aerosol particles from Segment 1 after                                                                                     6 dissolution esperiment in the flow through system ..............................

Figure 7. An alpha spectrwn of the aerosol sample determined on an electroplated 7  ; sample by using a surface barrier detector and pulse height analyser ........... S l ? e i L __.-__ _ _ . _ . ___ _, _

ACKNOWLEDGMENT We would like to thank Drs. R. O. McClellan and 8. B. Boecker for valuable discussions and suggestions during the course of this study. We are indebted to Drs. M. 8. Snipes. R. G. Cuddihy and S. H. Weissman for their critical review of the manuscript. We thank Mr. Donald A. Nitti of General Public Utilities (GPU) Services Corporation for providing the air filter samples. We acknowledge Ms. Sally Burt's contributions in the in viero dissolution studies and the contribu-tions of Mrs. Ancilla Bay, Mr. Ken Ahlert and Dr. R. A. Guilmette in the alpha spectroscopic analysis of the samples. . t 9 1

CHARACTER!ZATON OF AN AEROSOL SAMPLE FROM THREE MILE ISLAND REAC G. M. Kanapilly. J. A. Stanley. G. J. Newton. 8. A. Wong and P. B. DeNee EXECUTIVE

SUMMARY

The accident which occurred at the Three Mlle Island Unit Two Nuclear Generating Plant on March 28, 1979 resulted in contamination of the containment and auxiliary buildings. Analyses were performed at this laboratory for: (1)radioisotopiccompositionand(2)dissolutioncharac-teristics of material collected on a filter during a week of continuous air sampling in the auv-iliary building. This work was done to help characterize the environment in which cleanup opera-tions are being performed. Gamma and alpha spectroscopy along with scanning electron microscopy were employed to determine the elemental and isotopic composition of the aerosol. The major 134 I37 Cs. Dissolution behavior of the radioisotopes found on the filter were 895r. 9037, Cs and aerosol in a synthetic serum ultrafiltrate containing OTPA was determined using both static 89 90and In both systems, rapid dissolution of greater than 907, of both $r and flow-through systems. 134-137Cs was found. Only slight differences in the dissolution rates of Sr and Cs were ob-served. Scanning electron microscopic analysts showed the presence of respirable size particles as well as larger particles ranging up to 10 um. The major matrix components were Fe Ca. 5. Mg. Al and St. Except for Al and St. all matrix materials dissolved in the in utero dissolution systems. Although the radionuclides were present in a heterogeneous matrix, their observed rapid Knowledge of such a dissolution behavior justified their classification as Class O compounds.I classification enables better evaluation of bicassay data and predictions of dose distribution af ter inhalation exposure to this aeroso). The techniques used in this study may be applicable to other aerosols of unknown composition. INTRODUCTION. , The Three Mlle Island nuclear reactor accident in March 1979. resulted in the contaminat of the contain.nent and auxiliary butidings. During the cleanup operations of the auxfifary butiding, airborne radioactive fission products were encountered. The potential inhalation of these aerosols by workers and others involved in the cleanup prompted the characterization of the aerosol. In addition, knowledge of the characteristics of this aerosol could provide some infor-mation on the nature of the release. Thus, the quantitles, distributions and the physicochemical foms of the radioactive isotopes were the primary data needed. Data on elemental composition, size characteristics and other relevant physicochemical properties of the aerosoll were also desirable. The dissolution behavior of an inhaled aerosol is one of the major factors that determine its retention, translocation and resulting dose distributton.I Since the nature of the aerosol from the auntliary building of the Three Mile Island (TMI) was not known, there was no basis for predicting its dissolution in the lung af ter inhalation deposition. An important variable af-fecting the dissolution rates is the solvent. A solvent which has been used extensively for in vitro dissolution studies of several radionuclides in a variety of chemical foms is a synthetic I serum '4 ultrafiltrate. The in vitro dissolution of many aerosols in this solvent were qualf- " Therefore, h tatively comparable to their in vivo dissolution in the lungs of animals.3'8 vitro dissolution studies on this aerosol were conducted using this solvent. Other auxiliary studies for charactertaing the aerosol included scanning electron microscopic (SEM) analysis, energy dispersive x ray analysts (tDXA) and alpha and gama spectroscopy. t .

  • MATERIALS AND METHODS Aerosot Sa pts 9

The aerosol sample, which TMI personnel supplied, was obtained by filtering about 10 cc of air from the auxiliary building on a 2-inch diameter, glass fiber filter during a period of about 8 days. According to the information supplied by personnel134 from the GPU Service90Corporation, the 89 5r, 2-45 Sr 90Y, 2-4% 137 Cs, 10% Cs, 60% isotopic concentrations were approximately 20% 140g ,,140La and 11 of 58 Co and Co. The sample appeared to be a thick, black deposit. Pre-60 sumably, this material contained normal room aerosol, combustion aerosol and other unknown aero-sols. The total 6 and y activity on the filter was about 3.5 uCf. The filter was divided into four segments (Table 1) with approximately 40% activity on each of segments 1 and 2 and 10% activity on each of segments 3 and 4. Segments 1 and 2 were used in the dissolution studies. Segment 3 was used for electron microscopic analysis and the fourth segment for determining isotopic com-position by radiochemical analysis. I Table 1 Radionuclide Activity (nC1) in the THI Aerosol Filter Samples as of 79305 (11/1/79) 137 Cs 134c , 9037,90y 893 , Sample _ 157 124 440 Segment 1 657 164 120 424 Segment 2 634 37 23 105 Segment 3 157 54 41 146 Segment 4 218 412 308 1112 Total 1666 Dissolution Two different dissolution systems, a flow-through system and a static system, were used in this study.2 In the flow-through system, the solvent was directly in contact with the particles. This dynamic dissolution system provides estimates of early dissolution rates. The static disso-lution system was a simpler system better adapted for long-term dissolution studies. In both dissolution systems, the samples were sandwiched between two Nuclepore* filters (100 nmporediameter)andsecuredinafilterholder. The flow-through filter5 holder was a 47 nn polypropylenefilterholder(MtI11 pore,Inc.). A Delrin* filter holder with both filter faces open to the solvent, was used in the static system. ThesolventusedinthisstudywasasyntheticultrafiltratecontainingOTPA(SUF+OTPA). The pH, ionic concentration, precipitating and chelating capacity of this solvent were designed The solvent pH was maintained between 7.3 and to be similar to that of serum ultrafiltrate.I' 7.4 by esposing it to 5% CO2 in air. Both dissolution studies were conducted at 37'C by main-tatning the dissolution systems in a water bath. A schematic of the flow-through system is shown in Figure 1. The solvent in a lucite reser-voir was pressurized with 5% CO2 in air. The maintenance of a 0.5 ml/ min flow rate required a pressure of 1.5 to 2.5 psig. A Gelman* filter cartridge with pore diameter of 0.2 wm was used as a profilter for the solvent. The etuant fractions were collected at 20 minute intervals during the first day and then at 30 minute intervals by using a fraction collector. 3

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1 I L. . _ _2J wenic sett se reeenies c oecese , b Figure 1; A schematic design of the flow-through dissolution system used to study the in > vitro dissolution of radioevc11 des present on an air filter sample collected in the auxiliary building at the TM! facility. l c-m. 1- ';, ,

                     -      ~1n the static syster, the etiter' assembly was placed in 100 ml of solvent in a 500 al con-                                                             f i
                   -tainer, sealed with a lid end then placed in the water bath. Solvent changes were made at 2, 4 and 18 houn and then every' 24 hours. The solvent was changed by removing the filter assembly e.

from the solvent and placing it in fresh sol'vesit. -. Analyete of Olenotvel.totivity ' - - Gamma activity dissolved inithe flow-through system was determined by counting the fractions y Ten milliliter

                   ,directly in a tecipan Autogame Counter (Model 8000) with a Na! crystal detector.                                                                                 ;
                     ' aliquots of the static system samples were counted in the same detector. Tctal dissolved beta activities were determineg by counti'ig 100 ul aliquots prepared on planchets in a Beclunan Wide
          "            Deta !! gas proportional counser.                                                                     ,

Undissolved activity remaining M the filter or total sample on segment four of the filter sample m rq analyzed by dissolving the activity in 7 M hcl at 80'C. After. dilution, aliquots were counted in the Wide Beta II counter and the Autogame counter. The filter retained < 15 activity, although some black residue waslstill present. The "$r."Y activities in the original serosol sample and in the dissolution fractions were I determined by precipitating "Y phosphate at pH S and counting the associated beta emissions. I Toial Sr was precipitated from the remaining solution at pH '10. Desemination of Cons Activisten Gasma activities in the aerosol samples were determined by counting for 17 hours in a co-2 aHal Go-Li detector with an active. surface area of 16 cm and a resolution of 1.4 kev at 622 ' kev. After the dissolution studies, the filter samples were also counted in this Go-Li detector system to determine the remain!ng gassa actuity.

                        .foonning Kisotter, attarossopy Deergy Dispersios X-ny Analyste
                                                                                                                         ^

Sasples were transferred onto polished carbon stubs by pressing the carbon stubs against the sample on the filter. Replicate carbon itub samples were obtained from the same aerosol filter and were observed in a JFOL findel JSM-35 scanning electron microscope (SEM). Energy dispersive

a. ray analysis (EDXA) of selected areas was performed by using a Li-drif ted $1 detector (Kevex
                                       ,('
                                                                                         , ;. , e ' **
                                                                                              +
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the secondary electron imaging mode of the SEM. All cicrographs were taken using 25 kV accel-erating voltage and about i na beam current. Alpha Spectroscopy An aliquot of the original aerosol sample in 7 M hcl solution was evaporated to dryness, re-dissolved in 3 M hcl and the iron was removed by ethyl ether extraction. The actinides were then electroplated on stainless steel discs from a NaHSO4

  • Na 2504 buffer at pH 2.10 h alpha activ-ities were determined in a 128-channel pulse height analyzer with a resolution of 14.8 kev per 2

channel. The detector was a 300 nes surface barrier silicon detector (Princeton Gama Tech). The duration of alpha counting and analysis was 19 hours. RESULTS A gama spectrum of the aerosol sample is shown in Figure 2'. All four segments had id6n-134 137 Cs. The amounts of the major radionuclides tical gama peaks with the same ratios of Cs to present in the different segments and the total aerosol filter are shown in Table 1. The activi-ties of 134 Cs and 137 Cs were determined directly from gama spectroscopy and the activites of 89 NSr NY and 5r on Segment 4 by radiochemical methods. The 5r activity was calculated by 89 89 subtracting Sr NY activity from the total observed 5r and 90Sr 90Y activity. The activities 89 5r in the other three segments were calculated from the I3I Cs activity in each of NSr NY and 89 3pj l37 Cs segment and the ratios of Sr- Y/ 137 Cs and observed in Segment 4. g 137Cs b- - Z 3 - . O O W " N,

                   >=

4 -

                    .J W

E - 1 4 Ca g34 Cs l 134Cs i i 3% 7 k t <l i i i 10 219 428 637 846 1055 1264 1473 1682 18 91 K.E.V. Figure 2. Gama spectrum of Segment 1 of the TMI aerosol as determined with. a coaxial Ge-l.1 detector. 5

l ' ures 3 and 4. respectively, as fractions of undissolved activity remaining on the filter versus elapsed time. Total gamma activity was directly determined on the filters before the samples were subjected to dissolution. The initial total beta ac2ivities on these filters were calcu-lated from the ratio of total beta counts in the Wide Beta Il counter to 137 Cs in segment 4 and 13 the Cs count on segment 1 (flow-through system) and segment 2 (static system). The undis-solved fractions were calculated on the basis of beta counts. The 90Sr 90Y activity, both ini-tial and those in the solutions were determined radiochemically. Sumation of all dissolved radioactivites and those remaining on the filter provided estimates of i'itial n amounts of. radio-activities within a few percent of those activities shown in Table 1. OS - 0.8 f.

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Figure 3. Dissolution of radionuclides in o i i --i T 7 7 7 T 77 a flow-through system expressed as frac- o 5 10 15 20 25 30 35 40 45 50 tion dissolved versus elapsed time. TIME HOURS OSr-O a, o m 0.7 '- J O 06 - e m 5 05 ' 2 3 0.4 ' - 2 O P O.3. O h O.2 -

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u Scanning electron micrographs of particlles 5/ rom gegmenS aerosol sample, and those from Segment 1 after dissolution in the flow-through system ere shown in Figures 5 and 6, respectively. Average elemental composition of a large number of particles from Segment 3 and 1 are shown in Table 2. 137 Cs counts, this An alpha spectrum of the original aerosol is shown in Figure 7. Based on 239Pu, 238Pu or 241 Am, sample represented about 4% of the total sample. The total activity of 30 Pu in this sample is 0.50 dpm. On this basis, an estimate of total actinide alpha acti-and vity on the original aerosol was calculated to be 13 dpm. S -

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                                     '                                                                                            Figure 6. Scanning electron micrograph of aerosol particles from Segment 1 of the TMI Figure 5. Scanning electron micrographs of                                                          filter after dissolution experiment in the flow-original aerosol sample from Segment 3 of the                                                        through system. Magnification 3000 X.

TMI filter. Magnification 3000 X. Table 2 Elemental Composition of the TMI Aerosol Filter Sample

                     ~

as Determined by ' Energy Oispersive X-Ray Analysis . Weight Atomic Standard (t) (%) Deviation Element Segment 3 Before Dissolution 7.2 9.6 2.9 Mg 16.2 19.3 1.6 Al 27.1 31.1 1.5 Si 17.3 17.4 1.1 5 18.0 14.4 0.93 Ca 14.3 8.2 1.0 Fe Segment 1 After Dissolution 63.8 64.8 7.9 A1 36.2 35.3 3.2 Si , , 7

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Z "3 Figure 7. An alpha spectrum O 16 - of the TMI aerosol sample o determined on an electroplated sample by using a surface uJ barrier detector and pulse 2 12 - 23sPu S756 Kew height analyzer. p

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( i I t t t g 4724 4907 5089 5272 5456 5637 5820 6003 K.E.V. DISCUSSION 137 134 Cs were the primary Analysis of the gama spectrum (Fig. 2) indicated that Cs and gama-emitting radionuclides on the filter. The data supplied by GPU suggested the presence of 60 small quantities of 140Ba, 140La and Co. Since the gamma spectrum (Fig. 2) was obtained about a month after the aerosol was collected, it was expected that no 140 Ba or 140 La would be ob-134 Cs, could have been interpreted by TMI served. The energy peaks at 1168 and 1365 kev, from 60 p personnel as that of 58 Co and Co. It is noteworthy that there was no indication of any lan-144 Ce, present in the sample. thanide isotopes, such as 89 f The quantities and proportions of 134Cs, 9037,90Y and Sr (Table 1) were similar to the estimates provided by GPU. All data indicated that the* major radionuclides were 134Cs, 137Cs, 89 l 5r and 90Sr 90Y If there were other beta-emitting lanthanides, they would have been notice-90 able during the repeated counting of the Y fractions obtained during the radiochemical analysis 90 ! of 90Sr 90Y The half-time of decay of the Y fraction indicated no major, long-lived lanth-anide isotopes. The observed actinide radionuclides (Fig. 7) were unexoected. Although the alpha activity was only 13 dpm in the total aerosol sa@le, it is a significant observation that there were actinide nuclides present in the aerosol. Since the physicochemical behavior of lanthanide and actinides are similar, there may have been minute but undetectable amounts of gamma- and beta-emitting lanthanide radionclides also present in the original aerosol. The presence of r3jor isoto;.as of alkali and alkaline earth elements, which are generally 144 9I Y in detectable quantities sug-water soluble, but not other fission products such as Ce and gest that the major release mechanism was probably one of dissolution in watcr and then disper-sion in the auxiliary building. In addition, the presence of the small amount of insoluble actinide suggests other possible mechanisms of particle release as a minor contributing factor. The elemental analysis (Table 2) suggests that the aerosol consisted of nonradioactive materials. Comparison of the composition before and after dissolution suggests that only Al and Si were insoluble and the other elements were present as soluble materials. The radionuclides were 8

   . -presenT as The aluminum and silicon represented 43% of the total inorganic mass. It carbonaceous material.                                                             The filter sample was should be noted that the EDXA was incapable of determining C, 20 , H2 , etc.

black both before and after dissolution which suggested the presence of soot or other carbonac-eous materials. The sizes of the aerosol particles were estimated from the electron micrographs (Figs. 5 and Respirable-sized particles as well as larger particles ranging up to 10 um were observed. 6). 1 Although the relative number density of the particles .in the electron micrograph after dissolu-tion- (Fig. 6) was less than that before dissolution (Fig. 5), there was no apparent size-Therefore, it is not possible dependent, preferential dissolution of particles from the filter. from our study to deduce the size distribution of the soluble fraction which contained the ra-dionuclides. However, it is reasonable to conclude that at least a fraction of the radionuclides were associated with the respirable-size particles. The The dissolution data (Figs. 3 and 4) show rapid dissolution of > 90% of all isotopes. Less than 2% of the Cs isotopes appear to dissolve almost entirely in both dissolution systems. The data show Cs isotopes could be detected on the filters after the dissolution experiments. The total beta that within 5 hours, more than 95% of the Cs isotopes dissolved in both systems. It should dissolution rates were somewhat slower than the dissolution rates of the Cs isotopes.17 895r, 90 Sr N Y, 134Cs and Cs beta be remembered that the total beta activity was the sum of activities. The NSr NY dissolution rates suggest that a slightly higher fraction, 5 to 10% of the activity, was relatively insoluble compared with Cs. This undissolved fraction of the Sr was present in both dissolution systems. The International Comission on Radiological Protection (ICRP) has grouped specific chemical forms of radionuclides into three classes (D, W, and Y) to describe their expected patterns of retention in different portions of the respiratory tract.8 The three classes, days (D), weeks (W), and years (Y) describe both the expected clearance by mechanical and dissolution / absorpti pathways. These classifications have been derived for single radionuclides in known chemical foms based on available in vivo and in vitro data. However, the ICRP solubility classification scheme does not include predictions for heterogenous mixtures such as the one present on the sample analyzed here. Results from the in vitro dissolution tests performed on this sample demonstrate that most of the radionuclides present dissolved very quickly (within 5 hr) in the SUF plus DTPA solvent. Although an exact correspondence between in vitro and in vivo dissolution characteristics has not been established for these radionuclides in this fom and mixture, it seems reasonable to assume that a similar rapid dissolution would occur in vivo. Thus, based on this assumption and the observed in vitro dissolution characteristics of the present sample, it is appropriate to eval-uate observed air concentrations with respect to derived air concentrations (DAC) by classifying the radionuclides as class D materials. This study has demonktrated the applicability of the above te,chniques for characterizing ' The data may be useful in airborne radionuclides of unknown physical and chemical composition. determining the body burden of these radionuclides from bioassay data and helping to estimate the dose distributions resulting from inhalation of the aerosol. 9

     , .                                              Smuduim
1. Morrow, P. E., D. V. Bates B. R. Fish. T. F. Hatch and T. T. Mercer, ' Deposition and Reten-tion Models for Internal Dosimetry of Human Respiratory Tract " Health Phys. E: 173-207, 1%6.
2. Kanapilly, G. M., O. G. Raabe, C. H. T. Goh and R. A. Chimenti, " Measurement of In Fiero Dissolution of Aerosol Particles for Comparison to In Vivo Dissolution in the Lower Respi-ratory Tract After Inhalation," Health Phys. H: 497-507, 1973.
3. Kanapilly, G. M., O. G. Raabe and H. A. Boyd, "A Method for Determining the Dissolution Characteristics of Accidentally Released Radioactive Aerosols." in Proceedings of the Third International Congress of IRPA, pp. 1237-1242, Washington, DC, USAEC Document CONF-73907, 1973.
4. Kanapilly, G. M. and C. H. T. Goh, "Some Factors Affecting the In viero Rates of Dissolution of Respirable Particles of Relatively Low Solubility," Health Phys. M: 225-237, 1973.
5. Miglio, J. M., B. A. Muggenburg and A. L. Brooks, "A Rapid Method for Determining the Rela-tive Solubility of Plutonium Aerosols," Health Phys. E: 444-457, 1977.
6. Kanagilly, G M. and G. J. Newton, "A New Method for the Separation of Multicurie Quantities of 9uY from $0S r," Int. J. Applied Rad. and Isotopes E: 567-575, 1971.
7. Kressin, I. K., " Electrodeposition of Plutonium and Americium for High Resolution Alpha Spectrometry," Anal. Chem 4_9,: 842-846, 1977.
8. " Limits for Intakes of Radionuclides by Workers," ICRP Publication 30, Part I, pp. 63-116, 1978.

I f f t I i 1 l I L 10 l l l

AFFIDAVIT Randall C. Thompson I, Randall C. Thompson, worked at Threethat, Mile IIslandnn it II during the month of April,1979. Before had been a health physics and chemistry technician for RAD Services of Pittsburgh, PA and had held the title of Senior Plant Chemist at the Peach Bottom nuclear plant for the last two years of my nuclear career. For the first ten days to two weeks of my stay at TMI I was the only hp qualified as surveillance tech-nician to change the vent stack monitor filters. I also did containment sampling and provided hp coverage for the task of changing the banks of auxilary building charcoal filters. While working at TMI, I changed the vent stack nonitor filters twice a day. In every single case, the dose rate from these filters were very high, often constituting a "high radiation area" (more than 100 mr/hr. By way of comparison, consider that at Peach Bottom a four cubic ft./ min filter would yield a dose rate of less than 10 nr. Based on this, I came to the conclusion that the plant was emitting large quantities of radioactive gas through the vent stack. On two occasions, once in the EE counting trailer and once at the HP checkpoint I was able to look at isotopic identi-fication printout sheets from those filters. On both occasions iodine 131 was particularly high, showing concentrations of f one to five x10/-5 mc/ml. Of ten, because of the high dose rates of these filters, they were set aside so that noI one could disturb it before it was was asked specifically on two decayed to some degree. occasions to hide the filters. On both of these instances, when I went to retrieve the hidden filter it had already been taken. In all cases, the daily reports of radiation released from Thr,ee Mi.le Island were much lower than I personally observed. l

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se i ak %b I, nande&ph *hompson, From 1976 through 1979, I was the senior health physics ' and chemical technician, senior plant chemist and surveillance technician (air release specialist) at the Peach Bottom Fuclear Generating facility in Peach Bettom, Pennsylvania. As a health physics technician, it would be unthinkable rgdi to check for alpha radiation on a daily basis, under normal operating conditions where the possibility of alpha presence is practically nil. However, at TMI, where the conditions present indicated a stronger possibility for alpha contamination than normal, we were not able to check for alpha on a routine or spot basis. *his was because there were no alpha counters available. I continued to suspect alpha presence at TMI and inquired l of many people, including at least four NRC inspectors with whom I worked. I asked every utility person that I saw for an explanation a~s to why,there were not alpha counters available. The explanation was that there was no alpha, and, thus, no reason to check. This was unacc'eptable as an l l [ explanation since checking is routine. Upon further

                                                                                                                   ~

questioning, it was explained by Meted health physics employees that, indeed, during the first week after the accident, there was an " alpha scare", but after " independent analysis", it was determined that alpha was not alpha after all, but was " piggy-back beta".

Following the accidGnt, plannsd ralcaces waro schtdulsd end monitored. There was one situation where the monitoring system I tried to set up an alternative f ailed before the release. sampling system. Meted wanted to go ahead with the release prior to my setting up the alternative system which would not have taken more than 30 minutes. I pleaded my case with the head NRC person, arguing that legally or morally they coub". l not' go ahead. The NRC person stated that they had to go ahead, quipping, "Its the only game in town." The release  ! occurred, unmonitored. I lodged a complaint. To further identify this occurrence, it was in connection with the sampling of reactor water through the Auxiliary Building. h - l pm  % ~ k l . l

AFFIDAVI? Marian F'. (Joy) Thompson I, Joy Thompson, was employed by RAD Services, Inc. of Pitti-burgh, Pennsylvania as a health physics technician assigned to the Dosimetry department at Three Mile Island Unit II for the last three weeks.of April, 1979. My husband, Randall C. Thompson also worked at TMI as a ranking health physics technician and surveillance technician. Before the accident, my husband and I were incorporated as a publishing company, and published a monthly magazine for chil-dren.about skateboarding. Previous to that, my husband had spent seven years in the nuclear industry as a health physicist. When Three Mile Island had its accident, we decided to in-vestigate its causes'and effects first-hand, as the discrep-ancies in what we were hearing on the news and what we were i- hearing from our friends who were already working at TMI were 1 tremendous. During my employment at *MI, our friend and co-worker, David Bloombaum, was accidentally contaminated with radioactive iodine on his face and forehead. Nasal smears were taken before and after decontamination efforts by both David and my husband, and the geli identified the contamination as iodine. The body scanner, however, found none on the day of the con-l tamination. The next day, after navid had developed beta burns on the inside of als nose and the upper part of his throat, the MRC body scanner also found no iodine. It was my conclu-sion in this ' instance that the body scanners were not programmed to detect iodine. In my job as hp in the dosimetry department, I processed and recorded the daily TLD measurements for all personnel and visitors to TMI. The two TLD machines I used in that proce-ssing were the property of Metropolitan Edison and the NRC. Each concern was in charge of calibrating their own machine. I randomly placed groups of badges into one or the other machine to be ready depending on which was busy and which available. Often there would be discrepancies in one or the other machine's average dose measurement, when the average dosages should have been with.n a few MR of each other. When I would inform my superiors of the discrepancies, the machines would be re-calibrated during the day shift, but the differences in average dose measurement would grow each day thereafter until I would again have to complain to my super-iors. It was my belief that both machines were deliberately miscalibrated to underestimate actual dose. Once in mid-April, I was brought the worker's badges who were assigned by my husband to the task of changing the hanks of t gww'"9 -r-M='r-e-e-e-- $ wr.w y9 e,-- -m+y-eweei.e----w-e-+y--+' u-- - - -

2 charcoal filters in the auxilary building. The badges were usually brought over to the trailer from the island as each group of workers emerged from the aux building in order to immediately determine how much dosage they had received so as not to accidentally overexpose them. Most of the time a health physics technician would bring the badges, I would read and record the dosage immediately, then he would take that information back to the island. One time, a GPU executive engineer (management-level person) brought the badges for me to read. I was alone in the trailer and it was about two a.m. Despite the fact that the badges were . in blue cases (indicating whole-body dose as opposed to yellow badges which were used as extremity measurements) , I was given a direct order to intercept the computer documentation and enter the dosages as extremity. The doses ranged from.150 millirem to three hundred and fifty millirem...significant doses. Because those doses were entered as extremity doses, they did not become part of those worker's permanent dose

 ._      record.

The fact that the computer was programmed to disregard any dose reading under 10 millirem might not be significant in the operation of a normal nuclear power plant, but at TMI the doses were high and the badges were read daily instead of once or twice a month. Thus a person receiving 10 mr or less each day would have no record of any radiation exposure. In some instances, this practive could result in significant underestimation of dose and negation of legal rights if the worker were later to develop diseases caused by exposure to radiation. The underestimation of dosage and the deliberate cover-up of high doses at Three Mile Island is unethical behavior. I believe that evidence of unethical behavior by the utility should be a consideration in any decision to approve the , start-up of TMI Unit I.

                                                           /
                               /                              f           -

Statement of Carl J. Johnson, M.D. ,M.P.M. i (as a supplement .to the statement of the Aamodts to the to the Muclear Regulatory commission on May 22, 1985) There are oversights and miscongeptions in the Nuclear , l Regulatory Commission's Memorandum and Order, FLI-85-08 of May 16, 1985, responding to motions made by the Aamodts. Area household surveys of cancer incidence.and mortality are a more valid approach than the state's-use of concentric circles, when those areas lie in the usual direction of exhaust plumes from an industrial point source like TMI-l and TMI-2. What the NRC characterizes as " anecdotal information"

is the same information that physicians value as medical history, or that the Bureau of the Census considers to be vital census data. The information necessary for a valid cohort study must be obtained 'from area household surveys, it cannot be obtained from state cancer registries.

The radiation exposures to the communities around Th'ree Mile Island began in 1974 with the start-up of TMI-1. This plant also.had serious problems, had a chronically-leaking PORV, or pressure relief valve, and nearly had the same sort of meltdown in 1977 that later occurred at *MI-2 in 1979. The responsibility for the excess cancer deaths in the communities near Three Mile Island must be shared by both plants. The same management responsible for the lying, the 1

               . cheating, the misrepresentation of the radiation releases of TMI-2 also operated TMI-l since 1974, and I believe that 4

TMI-l also released large amounts of radioactive gasses and particulates. This belief is supported by reports of a chronically-leaking PORV and an aborted meltdown in 1977.

                                                                                                           ~
  • An underlying prcblem with th2 nuclooreatchlishmant is the reliance on doctrine, which is treated as a matter of religious belief. The doctrinal approach to science was supposed to have been displaced centuries ago by the empirical aoproach. In this case, if an unusually high incidence or death rate from cancer is observed near two failed nuclear plants, sources of extremely potent carcinogens, we had better believe it, and not strive tortuously to find some spurious but plausible explanation.

If you choose to believe that the time since the TMI-2 accident is not compatible with some of the cancer deaths, simply consider TMI-1, which has also been a very dirty operation, releasing plumes of radioactive gases and particulates since 1974. The importance of the seven cases of neonatal hypothyroidism in 1979, when only 0.6 cases were expected, has been confirmed by the rates for this condition since, falling sharply in 1980 and 1981, and now down to 1 or 2 cases yearly. The opinions of the State Health Department here is asinine and inexcusible.- The tone of the NRC comments lead me to ask the Commission if their policy on radiation effects research has changed from that outlined in a 1962 Atomic Energy Commission memo addressed to the Commission.

                                                                "    The basic approach to the report would be to start with a simple, straight-forward statement of conclusions.

We would thus identify the. major questions that could be expected to be asked in connection with these conclusions. It would then be a straightforward matter to select the key

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              -                                                     Mcy 21,-1995    -

TRANSURANICS AND THE IMPACT ON HEALTH Carl J. Johnson, MD, MPH

  • A typical nuclear reactor like TMI-2 has about 97 tons of uranium 238
  • cnd.3 tons'of U-235. Although some reactors are also fueled.with plutonium, all operating reactors make large amounts of plutonium.

A typical reactor in a year will produce 100,000 to 600,000 curies of olpha-radiation emitting plutonium, 7,000 to 110,000 curies of americium, and 400,000 tc over one million curies of curium. Ench curie will exceed the Department of Energy's (DOE) maximum permissible body burden for 24 million nuclear workers, or 2.4 billion people. This

    . DOE exposure standard does not protect workers, however.      At Rocky Fl'ats, nuclear workers with less plutonium in their bodies than permitted by DOE had sharply increased rates of chromosome damage, even at only 14 to 10% of the permitted dosage of plutonium.

Put another way, a teaspoon of plutonium 238 would exceed the DOE exposure limit for 40 billion nuclear workers, or 4 trillion people, and even a small fraction of this maximum permissible dosage will cause severe chromosome damage. There are about 40 tansuranics of importance, like plutonium 238, produced in all nuclear reactors. Some are somewhat less toxic, some are more toxic. Plutonium and similar radionuclides occur in all tissues in the body in man, and become a permanent resident in the body. The excretion rate is very slow, about one-half would be excreted every 200 years.

        -In animals, plutonium causes cancer of the lung, bone, kidney, mammary gland, lymph nodes, nosothelium, and ten types of soft tissue cancer.

In one animal study, plutonium caused a cancer rate of 114% with a mean induction period of about one year. Many animals has two different types of cancer. Excess cancer-incidence has been reported in Rocky Flats workers and in the population living downwind in Denver. The children and young adults

-        in Arvada and the area near the plant in 1957, when an explosion blew out the filters at the plant, had a greater than four-fold excess of leukemia in 1969-1971 at the time'of the National Cancer Institute's Third National Survey of Cancer Incidence. I estimate that the Rocky Flats cxposures will cause more than 12,000 excess cases of leukemia and cancer           !

in the Denver area between 1960 and 1990, and a somewhat greater number will be affected by birth defects and non-specific effects on health. , This was the only Federally-supported study of cancer incidence around a Federal nuclear facility. An Environmental Protection Agency (EPA) report states that a nuclear reactor can routinely release over a million curies of fission products in the exhaust each year. These routine releases include 6.8 curies of neptunium, a transuranic. I asked an EPA regional radiation officer why the release of the other 40 plus transuranics were not reported, and he said "that would not be self-serving to the industry." 0 42 Hillside Drive, Denver,'CO 80215 (303) 232-2328 I

a F , . s 200 North Church Street (Dak 203) Parkesburg, Pennsyh/ania 19365 April 26,1985 Thomas R. Combs, Chief Correspondence & Records Branch U.S. Nuclear Regulatory Comission Washington, D.C. 20555

Dear Mr. Combs:

Thank you for your letter of April 25 which identified Mr. Zech. Would you kindly send Mr. Gary G. Zech's resume'? Further, on March 11th I wrote the Commissioners to request letters from citizens that were placed on the Commissioners' table prior to the February 13th meeting (1985). I also requested the transcripts of the Citizens' Advisory Committee meetings with the Commission where our motions were discussed. There has been no response from the Commission concerning these provisions.

             ~

The Commission has made no response to my March 11th letter. I would appreciate a response. In addition, I am enclosing a copy of a postal card communication we received this morning. The writer, Larry Shulte of Silver Hill, Bradford, New Hampshire 0321 Indicates that Mr. Frank Ingram of NRC replied that he was not sure whether we ever provided the NRC with a copy of our " report". Mr. Shulte is referring to our motions of June 21,1984 and January 15, 1985 concerning health effects in the TMI area. We are deeply troubled by what appears to be a withholding of - Information. We request that you inform Mr. Shulte that NRC has these motions and what procedures he must follow to 'obtain them. Kindly send us all communications including those between Messrs. Shulte and Ingram. We would note that this is not the first time that we have been i notified that NRC has denied knowledge of our motions. Sincerely.

6%.' 9 s% ( W 9 L. .sk Marjorie 'M. Aamodt 4

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        - /'     "g                           UNITED STATES
     ,8            o             NUCLEAR REGULATORY COMMISSION F,         I                      stAsHINGTON, D. c. 20666
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April 30, 1985 t Ms. Sandra Blackington R.F.D. Sunapee, New Hampshire 03782

Dear Ms. Blackington:

l This replies to your April 22 letter. Mr. and Mrs. Aamodt have provided this agency with a copy of their report; however, there are not extra l copies available for distribution to members of the public. I suggest you contact the Aamodts directly to obtain a copy. Their mailing address is 200 North Church Street, Parkesburg, Pennsylvania 19365. In closing, i I am returning the stamp enclosed with your letter. Sincerely, M *-  % i Frank Ingram Assistant to the Director Office of Public Affairs l l l l l 1V I s f l ,I

 ?                       g                            UNITEJ STATES NUCLEAR REGULATCRY COMMISSION ,

h.f t a u. h a WASHINGTON,C. C. 20666 1 f, '%*****f l l April 30, 1985 Mr. Pater Meyer i Environmental Science Department Massachusetts Audubon Society Lincoln, Massachuseets . 01773

Dear Mr. Meyer:

This replies to your April 24 postcard. Mr. and Mrs. Aamodt have provided this agency with a copy of their report; however, there are not extra copies available for distribution to members of the public. I suggest you contact the Aamodes directly to obtain a copy. Their mailing address is 200 North Church Street, Parkesburg, Pennsylvania 19365. Sincerely,

                                                .                           1
                                                              ' 'Mc      9%

Frank Ingram Assistant to the Director Office of Public Affairs s O e en a 9 4 O e i _}}