ML20128H087
| ML20128H087 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/02/1985 |
| From: | Molholt B FRIENDS OF THE EARTH |
| To: | |
| Shared Package | |
| ML20128H085 | List: |
| References | |
| OL, NUDOCS 8507090403 | |
| Download: ML20128H087 (4) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4/Wh Before the Atomic Safety and Licensino Board In the Matter of
)
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Philadelphia Electric Company
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Docket Nos. 50-352
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50-353 (Limerick Generating Station,
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Units 1 and 2)
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AFFIDAVIT BRUCE MOLHOLT, Ph.D., being duly sworn, deposes and says:
1.
I am Adjunct Associate Professor of Health Education, Temple University, Philadelphia, Pennsylvania 19122.
2.
My Ph.D. is from Indiana University, Bloomington, Indiana (1967).
Postdoctoral training in molecular genetics was received from Karolinska Institutet (Stockholm, Sweden), the University of Ghent (Ghent, Belgium) and the University of Heidelberg (Heidelberg, I
Federal Republic of Germany).
I have taught and con-ducted molecular genetic research at the University of Kansas, University of Geneva, Czechoslovak Academy of Sciences, Haverford College and Bryn Mawr College.
I have taught and conducted research into the molecular basis of carcinogenesis at the Medical College of Wisconsin, Haverford College and Bryn Mawr College.
3.
My field of specialization is genetic toxicology with emphasis on the molecular genetic basis of human 8507 ]O g g5M0!52 QDR PDR WMffM6*A/T~ l
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carcinogenesis.
I have conducted research end published papers on human prostatic carcinoma, human breast car-cinoma and the mutagenic specificity of chemical carcinogens.
4.
The purpose of this affidavit is to demonstrate-that human health risks from liquid and airborne-effluents of the Limerick Nuclear Station have been underestimated by Philadelphia Electric Co. and by the U.S. Nuclear Regulatory Commission.
This affidavit is filed in support of contentions by Robert Anthony and Friends of the Earth.
5.
Exposure to airborne radionuclides at 270 m, the closest point of access, will be ten times more intense than at either 790 m or 762 m, plant boundaries assumed in the Environmental Impact Statement, assuming a simple diffusion model, e.g.,
during meteorologic inversion.
There is no reason to assume that a given individual would spend more time at 790 m or 762 m than at 270 m or other proxi-mal points along the Schuylkill River.
P6db Shsod<tr RGP.12fes AlW6H b, Ft 6xi.n. 2-6.
Liquid radionuclide exposure from fish will be more intense than calculated,1f fish are consumed the day of the catch.
This is due to both bioconcentration of radionuclides with short half-lives and the biologic half-lives of radionuclides in contaminated fish.
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7.
Tritium has been released from Limerick Nuclear Station and will continue to be released into drinking water supplies during plant operation.
Samples during the initial 10 days of criticality show a linear dilution of tritium activity with distance downstream from Limerick Nuclear ~ Station:
TRITIUM IN DRINKING WATER SUPPLIES (22-31 December 1984)
Drinking Water Supply Distance from Tritium Limerick (pCi/ liter)
Citizens 11ome Water Co.
2.4 miles 240 + 90 Phoenixville Water Works 5.2 miles 100 + 100 Philadelphia Suburban Water Co.
7.8 miles
<100 Oh9 LGS 0- 18, C-X t t From:
Regional Radiological Environmental Monitoring Program, Report #1, 22-31 December 1984, Limerick
--Generating Station (May 1985) (Tes6dvMG <%i Despite this linear dilution with distance from the~
Limerick plant, the above-cited report concluded "No significant difference in tritium activity was ob-served between the control and indicator locations."
The upstream control at Pottstown reported tritium at 150 + 70 pCi/ liter.
8.
As tritium moves up the food chain, it is incorporated into macromolecules, including DNA.
Tritium in DNA or DNA precursors is orders of magnitude more genotoxic than free tritium.
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4.
s 9.
Due to accidental dumping of floor drains into the Schuylkill River, 645 pCi iron-55 contaminated this drinking water supply from the Limerick Nuclear Station 21-31 December 1984.
Iron-55 will be built into heme as it mover up the foodchain toward man.
Heme containing iron-55 is leukemogenic.
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10.
Prior to full power testing, there is already evi-dence of genotoxic radionuclide contamination from the Limerick Nuclear Station.
Contamination of air and water by tritium, iron-55, krypton-85, xenon-133 and other radionuclides will increase during full power testing and operation.
Extant pathways from air and water contamination to man have not been adequately determined by the U'.S. fluclear Regulatory Commission in order to protect the public from routine radionuclide effluents of nuclear power plants.
In the case of the Limerick station, with a large nearby l
resident population at risk by both air and water routes, i
j this lack of public protection is particularly acute.
i
,$ ? Yl{ S BRUCE MOLHOLT, Ph.D.
Sworn to and subscribed before me this Mday of July 1985.
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