ML20149E202

R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition

ML20149E202
Person / Time
Site:	Three Mile Island
Issue date:	04/20/1994
From:	Gary R PENNSYLVANIA INSTITUTE FOR CLEAN AIR
To:
Shared Package
ML20149E051	List: ML20149E047 ML20149E202 ML20149E228
References
2.206, DD-94-03, DD-94-3, NUDOCS 9405260284
Download: ML20149E202 (3)

Text

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Statement Concerning the 10 Mile Rule f by Robert Gary, Senior Researcher  !

PICA, The Pennsylvania Institute for Clean Air i April 20, 1994  !

l The Director's Decision DD-94-03, Docket No. 50-289, License No.

DPR-50 (10 CFR 2.206) issued March 31, 1994, says on page 32 that no information has been presented concerning anything that has happened since 1984 to justify changing the ten mile rule and including Harrisburg in the federal emergency evacuation plans for the Three Mile Island nuclear site.

The ten mile rule is a policy decision based on considerations of what is " appropriate", what is " sufficient" and what is

" adequate" for the NRC to be in compliance with 10 CFR 50.47 (a)

(1) et seg. which provides for " reasonable" assurances for public safety for citizens living around nuclear power plants.

The ten-mile rule was not found by dividing Maxwell's Equation by the Golden Proportion. It does not arise from mathematical calculations in physics or any other science. There is no person that holds a Ph.D. in appropriateness, sufficiency, adequacy, and reasonableness for public safety assurances around nuclear power plants. The question is a combined technical / ethical / policy question that has no experts, has no formula, and depends on what we want to do in light of the circumstances.

Since the mid-1980's three things have happened which the NRC known about just as well as PICA knows about them and which bear on the question of what we want to do and what the circumstances are:

First: A nuclear reactor at Chernobyl melted down and contaminated half of Russia and half of Northern Europe.

Second: THI Unit 2 was opened up and it was found from the physical evidence that the 1979 accident was far more serious than originally reported to the public. 30 tons of fuel melted at temperatures of up to 5100 F degrees -- twice the 2500 F degree temperature which NRC Commissioner Victor Gilinsky was quoted as saying would warrant full evacuation. Two million gallons of highly radioactive water was produced, which was later evaporated releasing very significant amounts of radiation. 177 fuel bundles were destroyed and much Xenon was produced and released.

Third: on July 18, 1986 Jane Rickover, daughter in law of Admiral Hyman Rickover, said in a sworn affidavit (attached) that Admiral Rickover had caused President Jimmy Carter to suppress information in the public report on the accident which indicated that the accident was far more dangerous than was ever,made public.

Lt? i 9405260284 940517 PDR COMMS NRCC CDRRESPONDENCE PDR

r As PICA understands t.he NRC's current position the ten mile rule was made in the late 1970's by people who do not have Ph.D.'s in what is appropriate, reasonable or adequate. Since then a reactor has melted and contaminated about a quarter of the planet with major radiation releases. But that's not enough to justify reconsideration of the ten mile rule. Since then, we find that the physical evidence from the accident at Three Mile Island in 1979 indicates a far more serious accident than was presented to the public. ' But that's not enough to justify reconsideration of the ten mile rule. Since then, we find out that maybe there was a conspiracy in the oval Office of the White House to materially alter an official report the U.S. government so as to fraudulently conceal from the public the seriousness of the 1979 accident at Three Mile Island. But that's not enough to justify reconsideration of the ten mile rule.

What would be enough1 Do we have to lose a few hundred thousand people? Does the NRC have to be removed and replaced by a better Agency? Do some U.S. Senators have to be replaced? What would it take to obtain just a small moment of sweet Aeason in which we can re-assess whether 10 miles is still the line we want in the light of the circumstances we now know?

Why is re-assessment such a problem? Isn't thinking 'a natural act for human beings? Isn't survival a natural instinct? Doesn't the NRC have a duty to engage in thinking about such matters? Don't the citizens have a right to a thoughtful and responsive and accountable government?

Apparently not. The 2.206 process is being refined and developed.

The final refinement apparently will be to do the thing by autoteller machine. Petitioners can drop their petitions 5to the machine and they will get back a ticket that says "The Rules .You Have Questioned Are Indeed In Effect -- Have a Nice Day - Thank You For Your Concerns About Environmental Matters" This is the government that our forefathers died for. This is the government that is a shining light upon the hill for all nations to emulate insof ar as they are able. This government was created of the People, for the People, and by the People. Responsiveness and accountability are woven into its very fabric, part of every clause of our constitution, every stitch of our flag, every- 1 motive in our hearts. What happened to America? How did we get an Agency like the NRCI How did we get politicians who just don't ,

have what it takes to stand up and be counted on issues that are !

vital to the lives and health and safety of the People they 1 represent? PICA doesn't have those answers, but we urge people l reflect on the questions.

There are very good reasons to reconsider the ten mile rule.

Official refusal to do so is dereliction of duty of the most egregious kind. We urge the Commissioners to engage in reconsideration of our petition and of the points it raises l

including the ten mile rule.

h -- j

.n a bw

l Toronto, ::anada July 18. .986 In May,1983, my father-in-law, Admiral Hyman G. Rickover, told ]

me that at the time of the Three Mile Island nuclear reactor accident,  !

a full report was commissioned by President Jimmy Carter. . He (my :qather-  !

in-law) said that the report, if published in its entirety, would.have destroyed the civ4 7 4 an nuclear power industry; because the accident at ]

Three Mile Island was infinitely more dangarous than was ever mada .~public.

He told me that he had used his enormous personal influence with President I

Carter to persuade him to publish the report, only in a highly " diluted" form. The Pres + dant himself had originally wished tlie full report to be made public. l In November. 1985, my . father-in-inw t.old me .that he had come to deeply regret his action in persuading President Carter to suppress the most alarming :.spects of that report.

1.CL AA.f_. dLc r19 A ane. :Ri c kov er JANE RICX0VER appeared before me and swore as to the truth of the above statement.

Dated at Toronto this 18th day of July A 8 mwA William F.1.aeson Q.C.

Notary Public for the Province of Ontario pj !fii h~y.~l !;

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