ML19210C721

Preliminary Plan for Evidence Presentation on Psychological Distress Issue.Evaluation of Other Studies,Presentation of Own Studies,General Testimony & Conclusions by Expert Witnesses Will Outline Case.W/Certificate of Svc

ML19210C721
Person / Time
Site:	Three Mile Island
Issue date:	11/02/1979
From:	Jordan W, Sheldon K PEOPLE AGAINST NUCLEAR ENERGY
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7911200002
Download: ML19210C721 (6)

Text

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20 PUBLIC DOCIBEM M , et- -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4' ,o -f 6

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD v) ggr _.

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In the Matter of ) .,

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METROPOLITAN EDISON COMPANY, ) Docket No. 50-289 et al., ) (Restart)

(T hree Mile Island Nuclear )

Station, Unit No. 1) )

PEOPLE AGAINST NUCLEAR ENERGY PRELIMINARY PLAN FOR PRESENTATION OF EVIDENCE ON PSYCHOLOGICAL DISTRESS People Against Nuclear Energy (PANE) is in the early stages of developing the case that it will present on the issue of psy-chological distress. PANE has spoken to several potential expert witnesses and has investigated the various studies that have been or are now being done on the issue. On the basis of these discussions and investigations, PANE submits the tentative plan for presentation of evidence set out below.

PANE's case on psychological distress will consist of four par ts : (1) evaluation of studies done by others on the psycho-logical impacts of the accident, (2) presentation of a comprehen-sive study to be done by PANE 's expert witnesses on impacts in the area within five miles of TMI, (3) testimony of individuals concerning their own experiences, and (4) the conclusions of PANE's expert witnesses concerning the psychological and community health impacts of the TMI Unit 2 accident and of the renewed operation of TMI Unit 1.

In addressing existing and ongoing studies PANE 's experts will evaluate the quality of each study and how the study's Il  !)b 79122 co col

conclusions relate to the particular issues in this case. They will also explain the additional information that is needed in order to reach valid conclusions on the issues before the NRC.

In order to provide that additional information and to assure that the interests of its members and their neighbors and communi-ties are considered, PANE expects to conduct a comprehensive evalwation of psychological and community health impacts in the area within five miles of the reactors. This will be accomplished either by canvassing large numbers of residents or by selecting a smaller number through a sampling process. The choice depends upon the resources available to PANE and upon the advice of PANE's experts. In either case, the study will involve thorough psychological evaluation through both standardized testing and intense individual interviews. In addition, PANE will present evidence concerning property values, population changes, vanda-lism, business decline, and other indicia of community health.

The third part of PANE 's presentation will be the testimony of area residents about their experiences since the accident and their reactions to the possible renewed operation of TMI Unit 1. These witnesses will provide the Licensing Board with a representative sample of the psychological effects found by the various studies and by PANE 's experts .

Finally, PANE's experts will discuss their conclusions concerning both the long and short-term psychological and community health impacts of the accident itself and of the proposed restart of TMI Unit 1.

In presenting this plan, PANE emphasizes that it is tentative and may change significantly before the hearing begins. The

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Report of the President's Commission on the Accident at Three Mile Island, which includes a study on behavioral impacts of the accident, has only just been released, and other studies have not yet been completed. In addition, PANE has not been able to finalize arrangements with expert witnesses because the Commission has not yet decided to consider these issues. For that reason, thi.1 can only be considered as a tentative outline of PANE's presentation.

Respectfully submitted,

/OW#f0~ r William S.' Jordan, III .

Karin P. Sheldon SHELDON, HARMON & WEISS 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 (202) 833-9070 DATED: November 2, 1979 4

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY,

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et al., ) Docket No. 50-289 .

(Three Mile Island Nuclear )

Station, Unit No.1 )

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CERTIFICATE OF SERVICE -

.I hereby certify that a copy of " People Against Nuclear.' Energy Preliminary -Plah for Presentation of Evidence on Psychological ,

..' Distress" was mailed rirst class postage prepaid this 2n'd day of ,

November, 1979 to the following: ',, ..,'

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Secretary of the Commission (21) .

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Cl}ief, Docketing & Service Section James A. Tourtellotte, Esquire (4) .

Office of the Executive Legal Director U.S. Nuclear. Regulatory Commission Washington, D.C. 20555 Mr.' Steven C. Sholly ,1 - '

304 South Market Street 1-Mechanicsburg, PA'.17055 i

Jordan D. Cunningham, Esquire Fox, Farr & Cunningham 1 2320 North Second Street Harrisburg, PA. 17110 '

, Karin W. Carter, Esquire Assistant Attorney General 505 Executive House P.O. Box 2357 Harrisburg, PA. 17120 Frieda Berryhill Coalition for Nuclear Power Postponement 2610 Grendon Drive Wilmington, Delaware 19808

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Cert. of Service Docket No. 50-289 Ms. Holly S. Keck Anti-Nuclear Group Representing York 245 W. Philadelphia Street York, PA. 17404 .

Walter W. Cohen, Consumer Advocate Department of Justice .

Strawberry Square, 14th Floor .

Harrisburg, PA. 17127 .-  :,

Robert L. Knupp, Esquire =

Assistant Solicitor -

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. County of Dauphin ' ....

P.O. Box P *

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407 North Front Street .

Harrisburg, PA 17108 "'

Chauncey Kepford ~

Judith E. Johnsrud ,

Environmental Coalition on '

Nuclear Power ,

433 Orlando Avenue State College, PA. 16801 ~

John A. Levin, Esquire Assistant Counsel -

Pennsylvania Public Utility Commission '

P.O. Box 3265 ,

Harrisburg, PA 17120 Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street Baltimore, Maryland 21218 .

Kathy McCaughin Authorized Representative for Three Mile Island Alert, Inc.

23 South 21st Street -

Harrisburg, PA 17104 Marvin I. Lewis

' 6504 Bradford Terrace Philadelphia, PA 19149 Ms. Marjorie Aamodt RD #5 Coatesville, PA 19320 4 27' 7,

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_3 Cert of Service Docket No. 50-289 Ivan W. Smith, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 '

Dr. Linda W. Little

' 5000. Hermitage Drive ' - '

Raleigh, North Carolina 27612 ,~

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George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W. -

Washington, D.C. 20036 John E. Minnich

• Chairman, Dauphin County Board of Commissioners Dauphin County Courthouse Front and Market Streets Harrisburg, Pennsylvania 17120 h Sb.dep WilFfsm S. Jo'rdan , III f

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