ML20196B532

Affidavit of Cw Huver to Support Contentions 1,3 & 5.Svc List Encl

ML20196B532
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Site:	Three Mile Island
Issue date:	06/20/1988
From:	Huver C SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA
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Ii EXHIBIT D AFFADAVIT OF DR C.W. HUVER TO SUPPORT CONITlEIONS 1,3 and 5 8806300280 880620 PDR ADOCK 05000320 G PDR

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s UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

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GPU Nuclear Corporation ) Docket No. 50-320-OLA (Three Mile Island Nuclear ) (Disposal of Accident Station, Unit 2). ) Generated Water)

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AFFIDAVIT OF DR. CHARLES W. HUVER fCONTENTION 5)

Dated: June 20, 1988 b

Sworn and subscribed before me on this,7 d day of June, 1988.

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2 "7 INTRODUCTION My name is Dr. Charles W. Huver.. My business address is 8901 167th Lane, Forest Lake, Minnesota 55025. I~am an Adjunct. Professor of Saint Mary's College Graduate Center and am serving as a' witness for the Susquehanna Valley Alliance in this. proceeding. A summary of my professional qualifications and experience is attached hereto (curriculum vitae).

- DISCUSSION In Contention 5, the' Joint Petitioners hold that neither 4

detailed nor' accurate-information was given in the PEIS to allow decision-makers and the public to determine the effects of this proposed action on public health and safety, as required by NEPA (Memorandum and Order, ASLBP No.87-554 .

OLA).

In subpart (d), I would like to address the allegation that the serious biological effects of tritium have been undesestimated. An examination of PEIS Supplement No. 2 reveals that most of the literature on the biological hazards of tritium has been omitted and ignored.

Evidence for the biological concentration of tritium in the' literature is rare with most studies indicating no L concentration. However, Koranda and Martin (1969) have described some interesting tissue bound concentrations of i

tritium in the organs of small mammals living at Sedan l Crater. Animals were exposed for several generations to h

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tritium from their foods as well as tritiated water vapor from the air that they' breathed. Valves greater than unity were observed in the ratio of tissue-bound tritium to body water tritium.

Tissue fixation of tritium in food crop plants has been demonstrated by Koranda and Martin (1973) . They found t : 4 s single exposure of a corn plot to tritiated water resu.. in a fraction of 1.1% of the applied tritium present in the crop at time of harvest. Corn ears which had not been'. formed at the time of tritium application showed levels of 500 pCi/g which was closely correlated with the concentration of tritium in the soil water.

Koranda and Martin (1973) reported that any exposure of vegetation to tritium vapor or liquid will result in a variable amount of the tritium being fixed. They found that rapidly growing herbaceous crops produced greater tritium tissue fixation than that found in mature forest vegetation.

They suggest, "that as tritium concentrations in the biosphere increase, it may be advisable to develop maximum permissible concentrations for tritium in an organic form."

They also point out that few plant crop studies of tritium uptake in the field have been undertaken and that, "these data are needed for critical evaluation of many nuclear projects and operations."

Kirchmann at al (1971) have studied tritiated water incorporation after being applied as a spray on cow pasture.

They traced the transfer of tritium in forage vegetation to

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cow's milk. Higher levels of organically-bound tritium in milk were reported when cows ate tritium-contaminated forage than when they consumed tritiated water. These are the types of results-which led Koranda, Martin, and Anspaugh (1971) of the Lawrence Radiation Laboratory to conclude, "that tritium' I releases to the environment, even those of short-lived nature, have some ecological and biological consequence when evaluated in terms of human food chain effects."

Because tritium becomes incorporated in the CNA molecule (among others) the problem of genetic mutation and chromosome damage has to be faced. For instance, Gray (1959) has reported the remarkable result that -rays of the energy of I

tritium are about 2.5 times as effective in producing i

i chromosome breaks as are Y-rays. Assuming the often-held view l

l that chromosome breakage is one of the main causes of cell

lethality, one would expect that tritium p-rays would be about 2.5 times as lethal per unit dose as Y-rays.

It has been proposed that chromosome breakage is mainly produced by densely ionizing secondary electrons as they near the end of their tracks (Wimber, 1964). Chromosome breakage would then be more influenced by the number of secondary electrons per unit volume than to the total dose. High energy electrons from X- or Y-rays yield secondary electrons t that have energies of about 20 key. Considering that the mean energy of -rays is 5.7 key, then tritium should be about three times more likely than X- or Y-rays to produce chromosome breaks per unit dose. Data provided in Gray's m v +- w --

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table (1954) are in fairly good agreement with'Wimber's above hypothesis on the mechanism of the observed chromosome breakage by tritium, .

In 1957 Furchner studied the internal toxicity of tritium to mice and demonstrated that tritium -rays.were about 1.7 times as -effective as 7-rays in producing mortality in mice. Consistent'with the above findings, Furchner at al.

(1953) demonstrated that tritium -rays were more effective than Y-rays in causing damage to the bone marrow of rats.

Similarly, Worman et al (1954) found that tritium f-rays were more effective than 7-rays in producing thymic and splenic atrophy in the mouse.

That tritium can cause increased tumor formation in mice has been well demonstrated by Lisco gL al. (1961) and Baserga

- en al (19 62) . Upon injection of a 1 pc/gm dose of H 3-thymidine, they found that significantly more of these animals died form tumors than controls. Torok, Schmahl, Mayer and Kistner (1979) found that a single injection of tritiated wLter (0.27 mci tritium /g) caused an ovarian tumor incidence of exposed offspring five-fold over controls.

Rapidly proliferating germ line cells of the testes have shown a high degree of radiosensitivity to tritium exposure.

Studies by Oakbery (1955) and Johnson and Cronkite (1959) showed that the incorporation of H 3 -thymidine into developing mouse spermatogonia from doses as low as 1 pc/gm produced damage to spermatogonia and spermatocytes when examined 4 days after injection. Dobson and Cooper (1974) exposed

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female mice offspring from conception to relatively low experimental levels of tritiated water (0.085 pCi/ml) to produce a significant decrease in primary occytes as compared to untreated offspring.

The few reports in which the damaging effects of tritiated water and H 3 -thymidine are compared reveal a similarity of types of effects with tritiated water showing relatively less damage than H 3-thymidine. Painter at al.

(1958) studied the relative influence of THO and H 3 -thymidine on the growth inhibition of Hela S3 cells in tissue culture; the results showed that approximately equal growth retardations resulted from treatment with 5 pc/ml H 3-thymidine and 5 mc/ml THO.

Hori and Nakai (1978) chronically exposed human leucocytes for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to tritiated water and H 3-thymidine using a wide range of tritium doses. They found that at higher dose levels the yields of chromatid breaks increased linearly with dose, while those at lower dose levels were significantly higher than would be expected by a downward extrapolation from the linear model.

Doubtless, the most serious type of biological damage which has been demonstrated for tritium is that of genetic mutations. The fact that certain tritiated compounds become preferentially incorporated into DNA has led to the expectation that tritium within the chromosomes may cause high mutation rates. This predicted increase in mutation rates has been shown by Kaplan and Sisken (1960) and

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. s Stromnaes (1962) who induced sex-linked lethal mutations in Droscohila melanocaster by means of tritium-nucleosides.

Dominant lethals in mice leading to a 30% reduction in reproductive rate of offspring of H 3 -thymidine treated parents have been reported by Greulich (1961) . By means of injecting H 3 -thymidine into the tests of male mice, Bateman and Chandley (1962) found a definitie increase in abortions and estimated that 1% of the tritium disintegrations produced a dominant lethal mutation in the sperm.

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. 1 RECOMMENDATIONS

1. The experimental evidence suggests that the present I standards do not adequately protect the public health and safety because there is no evidence of a safe threshold.

2. Because of the large population subject to radiation risk and such irreversible biological damage as genetic mutations and cancer expected to be caused by tritium exposure, I recommend that the Atomic Safety and Licensing Board follow the principle recommended by the Federal ,

Radiation Council that of minimal exposure to the public.

3. The principle of minimal exposure leads one to reject evaporation into a populated area in favor of long-term storage on-site. The length of such on-site storage should be as long as possible with consideration for tank integrity. Let the natural decay of tritium activity in isolation minimize public radiation exposure.

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LITERATURE CITED Baserga, R., Lisco, H., snd Kisielski, W. 1962. Proc. Soc.

Expt. Biol. Med. 110:687.

Bateman, A.J., and Chandley, A.C. 1962. Nature. 193:705.

Dobson, R.L., and Cooper, M.F. 1974. Radiation Res.. 58:91.

Furchner, J.E. 1957. Radiation Res.. 6:483.

Furchner, J.E.', Storer, J.B., and Lotz, V. 1953. Los Alamos Sci. Lab. Rept.. LA-1544.

Gray, L.M. 1954. Radiation Res.. 1:189.

Greulich, R.C. 1961. Radiation Res.. 14:83.

Hori, T., and Nakai, S. 1978. Mutation Res.. 50:101.

Johnson, and Cronkite, 1959. Cited by Wimber, D.E. 1964. Adv.

in Radiation Biol.. 1:85.

Kirchmann, R.J., Van Den Hoek, and Lafontaine, A. 1971.

Health Phys., 21:61.

Koranda, J.J., Martin, J.R., and Anspaugh, L.R. 1971.

Lawrence Radiation Lab. UCRL-73546, p. 18.

Koranda, J.J., and Martin, J.R. 1973. In Tritium. ed by Moghissi, A.A., and Carter, M.W., USEPA, p. 430.

Lisco, H., Baserga, R., and Kisieleski, W.E. 1961. Nature.

192:571.

Oakberg, E.F. 1955. Radiation Res., 2:369.

Painter, et al. 1958. Cited by Wimber, D.E. 1964. Adv. in Radiation Bici., 1:85.

Stromnaes, O. 1962, can. J. Genet- cytol. '4:440.

Torok, P., Schmahl, W., Meyer, I., and Kistner, G. 1979.

IAEA-SM-237/24.

Wimber, D.E. 1964. Adv. in Radiation Biol., 1:85.

> 10 Respectfully submitted, 0

c JL M ' /%u Charles W. l'uve r, Ph.D.

Dated: June 20, 1988

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curriculum vitae Charles W. Huver, Ph.D.

Birth: Februar'y 21,1933 Place: Detroit, Michigan ,

Marital Status: Married, two children Address: 8901 - 167th Lane, N.E.

Forest Lake, Minnesota 55025 Phone: (612) 464 7235 .

Education: Michigan State University, September 1951 - March 1955 B.S.

University of Wisconsin, September 1955 - June 1957, M.S.

Yale University, September 1957 June 1961, Ph.D.

Speelal Study:

Michigan State University, Radiation Physics and Human Genetics, Summer 1953.

Kellogg Gull Lake Biological Station, Entomology and Parasitology, Summer 1954.

Marine Biological Laboratory, Woods Hole Marine Embryology, Summer 1956 and Summer 1957.

University of Connecticut Marine Laboratory, Noank, Ecologic Survey of Long Island Sound, Summer 1958.

Friday Harbor Laboratory, National Science Foundation Conference on Comparative Endocrinology, June 1967.

U.S. Environmental Protection Agency, Chicago, Region V, Water Quality Training Institute,1974.

Miami University, American Indian Concepts of Ecology, National Science Foundation Chautaugua Short Course,1977.

Positions Held:

Fishery Aid, GS 4, U.S. Fish and Wildlife Service, Kodiak Island, Alaska, 1955.

Teaching Assistant, Yale University, 1957 59.

Instructor in Zoology, University of Rhode Island, 1962 62.

Assistant Professor of Anatomy, University of Illinois, 1962.64.

Associate Professor of zoology, University of Minnesota, 1964 1982, Curator of Fishes University of Minnesota, 1966 1982.

Visiting Professor, Kellogg Gull Lake Biological Station, Summer 1967.

Visiting Investigator, Biology Department, Southeastern Massachusetts University Summer 1975.

Visiting Scientist, State of Maine Department of Marine Resources Laboratory, Boothbay Harbor, Summer 1980.

Research Director Environmental Concerns, Twin Cities,1982 present.

Adjunct Professor, Graduate Center, Saint Mary's College, Minneapolis, Minnesota,1985 present.

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curriculum vitae i*S*

q Administrative Experience:

University of Illinois, College of Medicine, Head of Histology C urse comprised of a staff of five professors.

University of Minnesota, . College of Biological Sciencer, Zoology Department, Director of Honors Program for three years.

Environmental Concerns, Twin Cities, Minnesota, Research Director for various environmental projects. '

Scholastic Honors, Fellowships, and Awards:

Bausch. & Lomb Honorary Science Award, Battle Creek High School,1951.

General Henry H. Arnold Award, Hinman Scholarship,1952.

President, Michigan State University Zoology Club,1954.

President, Beta Beta Beta Biological Fraternity, Michigan State University, ,

1955.

Superior Student Scholarship,~ Michigan State University,1955.

W.A.R.F. Research Fellowship, University of Wisconsin, 1955 57.

Wisconsin Biological Division, Wood: Hole Scholarship, University of Wisconsin,1956.

American Cancer Society Atypical Growth Fellowship, Yale University, 1958.

National Science Foundation Summer Fellowship,1959.

National Institutes of Health Predoctoral Fellowship, Yale University,1959-61.

Theodore Roosevelt Memorial Award, Lerner Marine Laboratory, Bimini, The Bahamas,1961.

Sigma Xi Grant in Aid, Bingham Oceanographic Laboratory, Marine Biological Laboratory, Woods Hole,1963.

Lalor Postdoctoral Fellowship, Marine Biological Laboratory, Woods Hole, 1964.

Metro Clean Air Award for contributions to envircamental quality in the Twin Cities Metropolitan Area,1970.

Minnetonka Fish and Game Award for contributions to fisheries ma na gemen t,1970.

Elected to Corporation of the Mount Desert Island Biological Laboratory, 1978.

Research Grants:

1965 67:

Minnesota Graduate School Grant Sport Fishing Institute Grant Clear Air Clear Water - Unlimited Grant National Wildlife Federation Grant Sierra Club Grant 1968 67:

American Cancer Society Research Grant at Kellogg Gull Lake Biological Laboratory ar.d University of Minnesota.

University of Minnesota, Graduate School Research Grant

, National Science Foundation Undergraduate Equipment Grant i

currierium vitae Pase 3 Charles W. Iluver, Ph.D.

Research Grants (continued) 1976 82: \

University of Minnesota hiuskies Inc. Grant American Fishing Tackle hianufacturers Association Grant National Wildlife Federation Grant Courses Taught:

Yale University (Laboratory)

General Biology Cells and Tis:ues -

Vertebrate Embryology Comparative Anatomy University of Rhode Island (Lecture and Laboratory)

General Zoology Embryology. Histology Organic Evolution University of Illinois, College of hiedicine (Lecture and Laboratory)

Head, liistology course (directed 5 professors on staff)

Neuroanatomy ,

Gross Anatomy Organic Evolution  !

Kellogg Biological Station, hiichigan State University (Lecture and Laboratory)

Field Ichthyology University of Minnesota (Lecture and Seminar)

Comparative Anatomy The Development and Physiology of Fishes Fertilization and Early Development Developmental Biology Evolutionary Biology hfarine Diology Custent Problems in Environmental Biology Ichthyology .

Problems of Coastal Zone hianagement and Great Lakes Ecology Vertebrate B!alogy Environmental Aspects of Cancer Senior Seminar in Ecology: Environmental Quality Environmental Regulation, College of Law hiinnesota Fishes and Their Environment, Continuing Education and Extension O

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Charles W. Huver, Ph.D. t g

Professional and Honorary Societies:

Sigma Xi Minnesota Committee for Environmental Infortdation Tau Sigma Americsn Society of Zoologists Phi Sigma Great Lakes Research Foundation Beta Beta Beta laternational Oceanographic Foundation Phi Kappa Phi Society for Developmental Biology A. A. A.S. American Society of Icthyologists and Herpetologists A.I.B.S. American Fisheries Soc!cty The Oceanic Society American Littoral Society American Society of Limnology and Oceanography American Public Health Association Upper Mississippi River Research Consortium Citizen Organizations Concerned with the Environment:

Chairman, St. Paul Environmental Quality Advisory Board, Minnesota Environmental Defense Council.

Minnesota Environmental Control Citizens Association (MECCA), Board of Directors.

Clear Air Clear Water Unlimited, Board of Directors.

Muskies, Inc., Board of Directors.

National Audubon Society.

National Wildlife Federation.

The Wilderness Society, conservation Advisor to Minneapolis Jaycees.

Northern Environmental Council, Board of Directors.

Nature Conservancy.

Citizens for a Better Environment, Board of Advisors.

Citizens for Energy Conservation and Solar Development, Board of Directors.

Media Experience:

Television:

Coproducer and cohost of "People and Pollution" a six program series for WTCN TV, Channel 11, 1969 70.

Consultant to University Community Video for four programs: "The Monticello Controversy *, "The Tyrone Reactor Story", ' Agent Orange in Minnesota", and "Agent Orange in Wisconsin', 1975 78.

Guest on the Henry Wolf Show, two programs on problems of nuclear power in Minnesota, KSTP TV, Channel 5,1970 and 1980.

Consultant to Jayson Davis on series about Agent Orange, KSTP TV, Channel 5,1975.

Guest on Delta College, Midland, Michigan, educational TV, two programs on environmental effects of nuclear power,1974.

Guut on Dave Moore News.,WCCO TV, Channel 4, to discuss the accident at the Prairie Island plant,1980.

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curriculum vitae Page 5 Charles W. Huver, Ph.D.

Media Experience Television (continued) s Consultant to Larry Schmidt's Consumer Report, WCCO TV, Channel 4, on the contamination of milk in Morrison County. Minnesota, with strontium 90,1978.

Guest on University of Minnesota educational course on physics to discuss environmental aspects of nuclear power, KTCA TV, Channel 2,1985.

Radio:

Guest on Henry Wolf program, five programs on environmental problems of Minnesota and the Great Lakes, KSTP radio, 1969 1976. ,

"Environmental Problems of Minnesota" series for American Lung Association, five programs played statewide un a network of stations, 1970.

"Energy and the Environment' seriet for Minnesota Public Radio, KSJN, 1980 81. (Four of these four minute interviews were played on National Public Radio's "All Things Considered'.)

Motion Pletures:

Technical consultant to Harvard University film "The Biology of fundulus heteroclitus".1957.

Advisor to Film In The Cities production of "Agdnt Orange: A Story of Dignity and Doubt',1979.

Bibliography of Technical Publications:

1956. The relation of the cortex to the formation of a perivltelline space in the eggs of fundulus heteroclitus. Biological Bulletin,11:304.

1960. The stage at fertilization of the egg of fundulus heteroclitus. Biological Bulletin, 119:320.

1963. The formation of melanophores in sembryonic eggs of Fundulus heteroclitus.

Copela, 1963:187 188.

1963. A chemical technique for dechorionating teleost eggs. Copela, 1963:591 592, 1964. Comparative studies of blastodisc formation in tel' costs. American Zoologist, 4:319 320.

1964. A quantitative study of DNA in the testis cells of Fundulus diaphanus.

American Zoologist,4:320.

1965. Occurtence of a northern pike in Fisher's Island Sot.nd. New York Fish and Game Journal,12:113.

1956. The distribution of sex in the American ect, Anguilla rostrata. American Zoologis t, 5:358.

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curriculum vitae Page 6 i Charles W. Iluter, Ph.D.

. Bibliography of Technleal Publications (continued):

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1966. The effects of mersalyl on the formation of the teleost blastodisc. The Bulletin of the Mount Desert Island Biological Laboratory,6:23 24.

1976. The geographical distribution of sex in the American cel, Anguilla rostrata.

Proceedings of the Joint Oceanographie Assembly, University of Edinburgh, Scotland, September 13 24,1976, pp.l.13.

1981. (With Charles A. Lessman) Quantification of fertilization induced gamete changes and sperm entry without egg activation in a teleost egg.

Developmental Biology, 84:218 224.

Bibliography of Studies and Reports:

1965. Comments on the expected influence of heated discharges from A.S. King Generating Plant Unit No. I on the aquatie life of Lake St. Croix A report presented to the liinnesota Water Pollution Control Commission, St. Paul, Minnesota.

1966. The water quality and uses of the Mississippi River between Anoka and Lake P; pin. A statement submitted on behalf of Clear Air Clear Water Unlimited to the Hearing on Proposed Water Quality Criteria for the Mississippi River, Minnesota Water Pollution Control Commission St. Cloud, Minnesota, 1967. A study of the effects of thermal effluents on the limnology of Lake St.

Croix. A progress report oc the preoperational phase of the study submitted to the Sport Fishing Institute and the National Wildlife Federation, Washington, D.C.

1968. Statement on water quality of Lake Superior. Submitted for a Public Hearing of the Minnesota Pollution Control Agency, Duluth, Minnesota.

1969. A critique of the Tsivoglou Report on Radioactive Pollution Control in Minnesota. Clear Air Clear Water - Unlimited Newsletter, South St.

Paul, Minnesota.

Biological effects of tritium. A report presented to the Minnesota Pollution Control Agency, St. Paul, Minnesota.

A critique of the permit for the Monticello Nuclear Generating Plant.

Presented on behalf of the Minnesota Environmental Control Citizens Association to the Minnesota Pollution Control Agency, St. Paul, Minnesota.

Perspective on the pollution 'of Lake Superior by taconite tailings.

Proceedings of a Conference on Pollution of Lake Superior and its <

Tributary Basin, hiinnesota-Wisconsin Michigan, Vol. 40.

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O curriculum vitae Page 7

, Charles W. Huver, Ph.D.

Bibliography of Studies and Reports (continued):

A survey of pollution problems in Minnesota. A report submitted to Midwest Associates, Inc. Minneapolis, Minnesota.

1970. Perspective on the pollution of Lake Superior by taconite tallings. Twin Cities, March 1970, Minneapolis, Minnesota.

- Biological hazards of tritium. Presented at a Congressional Hearing on Atomic Energy Plants and their Effects on the Environment, New York, New York.

Thermal and radioactive effluents and the effects on our waters. h!!nnesota Journal of Education, Vol. $1: No.1; October,1970.

Periphyton growth as an index of aging in Lake Superior. Proceedings of a Conference on Pollution of Lake Superior and its Tributary Basin, h!!nnesota Wisconsin h!!chigan, Vol. 2.

Biological effects of radioactive effluents. In The Ecology Controversy.

pp.4145. Anoka, Minnesota: Greenhaven Press.

Public health re: tritium. In Statements and Questions: Nuclear Power and Public Concern, p.14. Washington,' DC: National Committee to Stop Environmental Pollution.

1981. The Minnesota low level radiation study. In Frogs in Hot Water, pp.1214.

Ardsley, NY: Independent Citizens Research Foundation for the Study of Degenerative Diseases, Inc.

Published Books:

1973. A Bibliography of the Genus Fundulus. Boston: G.K. Hall & Co.,138 p.

1979. Huver, C.W., Dixon, G.A., Jacobson, N., and Dixon, G.I. Methodologies for the Study of Low Level Radiation in the Midwest. Millville, MN: Anvil Press,188p.

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CERTIFICATE OF SERVICE I hereby that copics of the foregoing "SVA/IMIA'S RLcPONSE 'ID LICENSEE"Mf[yifl0 FMION FOR SlitiARY DISPOSITION ON Cot (1TRrIONS 1,2,3,4,Ed,6 and 8" and Exhibits A,B,C and D were served this day of June 23rd.by Prio ty M 27 PS:35 Mail to all parties on the service list,excepc those noted with a[0c'[C T'% - s 1;a . v"ict

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asterisk,who will receive this mailing by Express t42il.

L Frances Skolnick t

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1 SEm17CE LIST 4 Sheldon J. Wolfe, Chairman Admtnistrative Judge Atomic Safety and Licensing .

Board Pane 1 U.S. Nuclear Regulatory Cornni s s i on -

Washington, D.C . 20555 4 G1enn O. Bright T h en,a s A . Ba.ter, Esq.

Administrative Judge Shaw. Pittmen, Potts &

Atomic Safety and Licensing Te cmb,' i dg e Board Panel 2300 N Street, N.W.

U.S. Nuclear Regulatory Commission Washington, DC 20037 Washington, D.C. 20!!!

Dr. Oscar H. Paris Stephen H. Lewss. Esq.

g Administrative Judge Office of the General Atomic Safety and Licensing Counsel Board Panel U.S. Nuclear Regulator U.S. Nuclear Regulatory Cccan i s r i on Commission Washington, D.C. 20555 Washington, DC 20555 Dr . William D. Travers Ms. Vera Stuchinsk Dir. Three Mile Island Three Mile Island slert Cl e anup Project Directore 315 Peiter Street P.O. Box 311 Harrisburg, Pa. I?!02 Middletcwn, Pa. 17057 Dxketing & Services Bramh Richard P.thther Secretary of the Ccruission Apt. f Enviromental Resources 505 Executive ikuse U.S.N.R.C. Harrisburg,Pa 17120 Washington DC 20555.

R. Rogan, Director Licensing and Nuclear Safety Ut1 9 '

Middletom, PA 17057 9MW wC Frames Skolnick