ML20100L445
| ML20100L445 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/13/1985 |
| From: | Aamodt M, Aamodt N AAMODTS |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#285-558 SP, NUDOCS 8504160630 | |
| Download: ML20100L445 (41) | |
Text
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UNITED STATES OF AMERICA DCCXiTCc NUCLEAR REGULATORY COMMISSION U5hltc BEFORE THE COMMISSION
'85 !?R 16 1111 :43 CFF.CE Gr iwWp -
000XE7jNG ^ SERvict~
In the Matter of =RhNCH METROPOLITAN EDISON COMPANY, et al. Docket SG-2896h (Three Mile Island Nuclear Generating Station, Unit 1)
AMENDMENT TO AAMODT MOTION OF JANUARY 15, 1985 ADDITIONAL HEALTH MATTERS WHICH MUST BE CONSIDERED PRIOR TO THE COMMISSION'S DECISION ON RESTART OF UNIT 1 i
Norman O. Aamodt Marjorie M. Aamodt
/ 200 North Church Street l
Parkesburg, Pennsylvania 19365 l (215) 857-1608 i
April 13, 1985 i
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l 8504160630 850413 #
O l gDR ADOCK 05000289 2 PDR n._._.
Table of Contents AMENDMENT TO AAMODT MOTION OF JANUARY 15, 1985 ADDITIONAL HEALTH MATTERS WHICH MUST BE CONSIDERED PRIOR TO THE COMNISSION'S DECISION ON RESTART OF UNIT 1
- E^En' 1.0 Abstract ................................. 1 2.0 Introduction ............................. 3 3.0 Health Ef fects Beyond 10 Mile Radius of TMI 4 I
3.1 Neonatal Hypothyroidism Cases In Lancaster County ....................... 6 3.2 Recent Reports of Health Effects Beyond 10 Mile EPZ ............................. 9 3.21 Serious Post-Accident Health Effects Beyond 10 Mile EPZ Spontaneously Reported ..... 10 3.3 Serious Health Effects Beyond 10 Miles Acknowledged By GPU's Payout of Nearly 4 Million Dollars ...................... 12 a 4.0 Evidence of Radiation From TMI Presently in Environment ......................... 13 4.1 Measurements West of TMI by Agencies ... 13 5.0' New Information Concerning TMI-2 Core Temperature ............................ 16 4-6.0 The New Information Meets the Standards for Reopening the Hearing- .................. 18 7.0 Contentions .............................. 18 8.0 ' Discussion .............................. 19
. 9.0 : Conclusions ............................. 21 Exhibit 1 - Department of Energy 10-Mile Exposure Profile (mR) for the Period March 28 through April 3, 1979.
Exhibit 2 " Judge OKs $3.9 Million for TMI Suits",
The Evening News, February 7,1985 "17 County Youths to Get $181,700 in Settlement over TMI Accident",
New Era, Marchi6, 1985 Exhibit 3 - "A Time For Sharing And Caring",
Extra, March 20, 1985 Exhibit 4 . Radiobiology for the Radiologist, pp.65,70-73 Exhibit 5 - Diagram - Location of Core Material,
. Transcript, pp. 27,.28, Commission Meeting, November 7, 1984 Exhibit 6 - " Accident without an end", The Philadelphia Inquirer, section of pp. 7, Special Edition
'1.0 Abstract On June 21, 1984, the Aamodts reported to the Commission that their findings of serious health effects in residents in the direction of early plumes from the TMI accident clearly indicated that a comprehensive investigation was warranted prior to the restart of Unit'1. The Commission denied the Aamodts' motion on December 1984, following the NRC Staff's direction and a cursory review by the Centers for Disease Control. Commissioners Bernthal and Asselstine provided dissenting opinions.
On January 15, 1985, the Aamodts asked the Commission to reconsider its decision since the 600% increase in cancer mortality in the areas surveyed had been verified. Other scientists, the TMI Citizens'
- Advisory Committee and Senator Arlen Specter also asked the Commission to reconsider the Aamodt motion.
Although there has been no ruling, the Commission has publicly stated that it may initiate an investigation of health effects. However, it appears that the Commission would not delay its decision on restart of Unit 1. .
The Aamodts believe that the Commission must determine, prior J
t to its Unit 1 restart decision, the cause, extent and scope of the TMI-area residents' health problems and environmental injury. Serious health effects as far as 30 miles from TMI appear to be accident-related J and challenge the NRC's emergency planning for the 10 mile radius of TMI. The Aamodts have argued that since the people, flora, animals and insects were the true dosimeters, the dosimetric hardware and techniques, presently in use, have been demonstrated to be inadequate to protect the public and environment. In fact, residents in one area '
t nordiwest of TMI are presently experiencing effects which appear to i
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be the result of residual radiation from the accident, however the agencies responsible for the protection of public health cod safety claim that they are not able to identify causative radioactivity or any other agent.
The recently-acknowledged 5,100 degree temperature that the core of Unit 2 reached during the 1979 accident released transuranic materials from the core. These materials emit a type of radiation (alpha) which was not measured at the time of the accident, which is difficult to detect, which cannot be detected by the standard kind of dosimetry presently installed for the protection of the public, and which is highly hazardous.
Transuranic materials were probably released to the environment during the TMI accident, a matter which would challenge the legitimacy of further nuclear operations in the area. GPU admits that two to eleven tons of the Unit 2 care are missing, and transuranics were found in Unit 2 filters analyzed in 1980. The withholding of this information further calls into question i.he integrity of GPU management and NRC regulation of Unit 1.
GPU, in its pay-out of nearly four million dollars so far this year, has essentially admitted that IM1-area residents have been severely damaged by the TMI accident. A number of these residents reside beyond the 10 mile radius for which emergency planning has been provided. Over 300 additional personal injury claims have been filed. It can be assumed from these numerous claims and the findings of a 600% increase in cancer mortality west of TM1 that the TMI accident was a disaster of undefined proportions.
GPU's imposition of a ' gag' on claimants in return for out-of-court compensation will block access to information needed in a comprehensive investigation of health effects from the accident unless ' a challenge is made in the public interest. If Unit 1 is allowed to operate, prior to
the full resolution of the extent and nature of the radiological impact from the Unit 2 accident TM1-area residents may again experience ,
additional serious physical injury from an accident at Unit 1.
Any further delay by the Commission, relative to the fair and independent resolution of the health effects in the TMI area, would provide cause for criminal prosecution of the commissioners. In the event that the Commission should act to restart Unit 1 prior to a fair resolution of health effects in the TM1 area, legal action to remove the consenting commissioners would be appropriate.
2.0 Introduction By memorandum of March 14, 1985, we notified the Commission that serious post-accident health problems in persons residing beyond the 10 mile EPZ (emergency planning zone) for TMI must be included in a comprehensive investigation of health effects and that this investigation must procede the Commission's restart decision. The matter of serious post-accident health effects within and bevond the 10 mile radius of TM1 challenges the presently-approved emergency plans. tdhile the Commission now appears to be softening its attitude toward the initiation of a comprehensive investigation of post-accident health effects in the TM1-area residents, the Commission has signaled its intention to proceed with its decision on restart of Unit 1 prior to any investigation.1/
The Commission's apparent change in attitude toward our motion for an investigation of the health problems is commendable, however a 1/ See transcript of Commission meeting with Citizens' Advisory Committee of March 7,1985.
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'd restart decision would be premature -- and illegal -- if it precedes a health investigation.
The Commission must determine the extent of personal and environmental injury caused by the TM1 accident prior to a decision on restart of Unit 1, whereby further radiological injury is premised.
The Commission must determine whether the emergency plans developed on the basis of the totally false assumption that noone was injured, are adequate to protect a seriously-injured population.
The recently-acknowledged facts, that the TMI-2 core temperature exceeded 5000 degrees (fahrenheit) and that transuranic materials were found in filters, were not considered in planning protective actions for the public. In addition, the late admission by GPU of the extensive core damage, despite the telling evidence of transuranics in the filters, poses even more serious questions concerning the trustworthiness of the present management. The six year delay in any reasonable assessment of the severity of the accident, and the present reluctance to face the public health issues, by agencies that knew or should have known, has raised the issue of the adequacy of the oversight and regulation of nuclear operations at TMI -- or anywhere.
3.0 Hed.h Effects Beyond 10 Mile Radius of TMl The data is of three types. The first (presented in Section 3.1 and Figures 1,2) was routinely collected by the Pennsylvania Department of Health (PDOH) to ameliorate the effects of hypothyroidism in infants less than 28 days old (neonatal). The 1979 and 1980 data for Lancaster County is not new information, however a reinvestigation is now warranted in view of the significant drop in cases from 1981 through 1983. This drop was n_ot expected by Licensing Board, in separating the 1979 hypothyroidism incidence from the TMI-2 accident. See PID,
December 14, 1981,91721. If the 1979 cases were the result of radiciodine as appears to be the case, releases from the TMI accideat/the distances of the residences of these cases, as far as 35 miles from TMI, challenge the concept of emergency planning for the 10 mile radius.
The second set of data was provided, individually and spontaneous'y, by t.he affected persons after our motion of January 15, 1985 was reported in the news media. Although the data is sparse in comparison to the potentially-affected population, we consider the cases reported as representative of a large number of existing, unreported cases. Mhis data is presented in Section 3.2 and Figure 3. Its significance is its credibility (it is consistent with data concerning health effects within the 10 mile radius and, in a relative fashion, with radiation measurements made during the accident) and the distance of the affected beyond the 10 mile EPZ. ,
The third kind of data was gleaned from newspaper accounts of personal damage suits which GPU has tacitly admitted were valid in settling out-of-court for nearly four million dollars. At least seven of .the personal injurie's Vere- to children who reside beyond the 10 mile EPZ.
This information is presented in Section 3.3 and Exhibit 2.
2/ The Licensing Board's chief argument was that since the " rate of neonatal hypothyroidism in Lancaster County remained hich in the first nine months of 1980, long after radiolodine releases from the TMI-2 accident should have ceased...the increased rates in Lancaster County after the TMI-2 accident, were not a result of that accident." (The Board's assumption that the venting in 1980 was void of radiolodine is naieve)
The Board did not have other credible evidence since it '*was not convinced as to Dr. Tokuhata's (PDOH witness and chief epidemiologist) radiobiolobical expertise and understanding of genetics on which his conclusions regarding health effects were based." Id.11722.
3/ Since we have moved and have an unlisted telephone number, we can assume that many more people tried to reach us. The fact that these did, emphasizes their conviction. Residents within the 10 mile radius, in the areas surveyed last year, have called to report an additional 31 deaths and 46 cancer / tumor diagnoses in the arca and nearby.
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3.1 Neonatal Hypothyroidistr. Cases in tancaster County The significant drop in cases in the years 1981-1983 strips away 4/
the Licensing Board's (see Section 3.0 supra.) and the PDOH's beses for claiming that the 1979 incidence was not caused by the TMI accident.
The 1979 data represent.. a tenfold increase in incidence over that expected ( according to national averages (1 case /4000 - 5000 births)).
hlith approximately 3000 births, annually. Lancaster County should report one or no cases per year (0.06 - 0.07). The higher than expected rate in 1980, which misled the Board into 4 believing that incidence in Lancaster County Lancaster County was routinely above the national expected, can be attributed to the venting of TMI-2 containment gases in 1980.
The number of cases are provided by year in Figure 1 and plotted l by geographical location of residence in Figure 2.
FIGURE 1 - NEONATAL HYPOTHYROIDISM CASES IN LANCASTER COUNTY Year Number 1979 ............... 7 1980 ............... 4 1981 ............... 2 1982 ............... 0 1983 ........,....... 1 4
h Dr. Tokuhata has continued to attribute the high incidences of hypothyroidism in 1979 to genetic defects among the Amish, reiterating this absurdity as recently as this past fall in addressing a professional conference. Oral Presentation at the XII International Biometric Conference, September,1984 (written version provided by PDOH).
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FIGURE 2 - LOCATION OF RESIDENCES OF NEONATAL HYPOTHYROIDISM CASES
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IN LANCASTER COUNTY,1979 POST-TMI ACCIDENT Q
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almo RseIms ?83 y -f. 2 ' ast ff.h n, ,- '2 Ta Ne 7 230 PeteTsburg e\ Hollanc ork L28tl i.3 Mount L
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'oYf" saiong 28 2 Neil teaco k, -r'Ba r evill trines wn q Bainbridge l t4l t andisVi le 222 73 g Leola X Bamfor'dville 3 ,#,
'Mo olf"k Maytown
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, i :Ma chesterN #a 5 30 y . 462 A p.' < 6 t -
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The geographic distribution of the six (post-accident) cases (shown in Figure 2, pp.7) falls into a line in an east southeast direction from TMI, suggesting the impact of a plume from .TMI. .
Although one case was as close as approximately five miles from TMI, the other.five cases resided from 15 to 35 miles from TMI, or well outside the 10 mile EPZ.
Since the Board's and PDDH's explanations of the high incidence of hypothyroidism in 1979 in Lancaster County has been refuted by the evidence of normal incidence in 1981 - 1983, the identification of the geographical locations of the 1979 cases as far as 35 miles from TMI, as twell as the high incidence throughout southeastern Pennsylvania in 1979, must now be investigated for. Its implications concerning emergency planning.
The most recent study of the TMI-2 inventory has only 5/
accounted for between 17 and 28 percent of the radiciodine."
Extrapolations of iodine release from milk sampling has been shown to be too low by a factor of 50 because of an error of assumption 6/
that cows were on pasture 7 In addition, milk sampling at distances where hypothyroidism occurred was essentially non-existent.
The more reasonable interpretation of the hypothyroidism incidence exposure of pregnant women in 1979 weald be to consider / - to radiolodine from the accident.
The highest incidence was in Lancaster County where the Amish pregnant women were working in the fields (as is the practice) and consuming frgstt milk from the pastured family cow.
5/ ' Pelletier, et al., " Preliminary Results of the TMI-2 Radioactive lodine Mass Balance Study, Transactions Vol 43, American Nuclear Society Meeting, Idinter 1982, tdashington, D.C.
s/ Beyea, "A Review of Dose Assessments at Three Mile Island and Recommendations for Future Research, August 15,1984. C-55, Table C-5.
-9 The NRC Staff withheld a study which it commissioned to determine the Il pathway of radiciodine to milk. This study, which established the s/
pathway as totally to inhalation, if considered in the restart proceeding, would have led the Licensing Board to different conclusions concerning hypothyroidism data.
3.2 Recent Reports of Health Effects Beyond 10 Mile EPZ The persons who provided the following information believe, independently of any outside information, that the injuries that they have described are totally attributable to the accident at TMI. Their beliefs
- cannot be disgacded out-of-hand. in fact, the geographic plot of the cases, voluntarily reported, shows that the locations, geographically, are in to general direction.r north - west and south - east.
Not surprisingly, these are the directions where the official records show that radiation releases were highest. See Exhibit 1l attached.
Z/ Beyea, (Id.) pp.C53.
8/ Baker, et al., " Pathways to lodine-131 to Milk Following the Three Mile Island incident", Letter Report to NRC, Battelle Memorial Institute, t Pacific Northwest Laboratory, Richland, Washington, June 1983.
(The study had been completed eighteen months earlier.)
- Since the time of the ' accident, people who had problems associated ;
with TMI have met with denigrating official and medical reaction. The official position that 'not enough got out' was promoted by GPU among the local medical practioners. GPU hosted the TMI area physicians, (continuep after, accident, to inform them that any medical indications of radiation damage that they might observe in their patients could not be attributable to physical damage from the TMI accident.
It is believed that NRC personnel participated in this effort. l i
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3.21 Serious Post-Accident Health Effects Beyond 10 Mile EPZ Spontaneously Reported A description is provided and identified geographically on Figure 3 by corresponding letter.
(A) A baby, conceived within two weeks of the accident, with the following abnormalaities: a single eye located in the center of its forehead and hydroencephalus; died following full-term birth.
(B) Five cases of leukemia within a mile; one person in mid-30's died in March 1985.
(C) A 31 year old woman with hypothyroidism and leukemia.
(D) Four infants born in the same month with Downs Syndrome;
. incidence considered abnormally high by physician; one/ year expected. (this hospital).
(E) Three carpenters, working outside near the city of Lancaster, experienced metallic taste during the initial days of the accident; two developed lipomas.
(F) Siblings were diagnosed as having an identical mysterious blood disorder in May 1979.
(G) Dandelion leaves over 3 feet long grow in profusion in a school yard.
(H) A secretary in the Capitol building experienced metallic taste, nausea and severe vomiting on the first day of the accident, causing her to leave work and seek a physician's advise.
(I) A woman (less than 35 years old) has hypothyroidism and cancer of the cervix.
(J) A young woman has experienced a spontaneous abortion, death of an infant and a recent diagnosis of breast cancer.
(K) Cancer cluster.
FIGURE 3 - PLOT OF REPORTED SERIOUS HEALTH EFFECTS BEYOND 10 MILE RADIUS OF TMI 20 7-o Dauphin k -'
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Starysville ! ,/
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ne M 3, 10 Camp (dH(1 (G) s hirema town [* an g pire f g Stec icsburg letow n A /
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( TliREE hilLE ISLAND
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1 Wellsville
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ichtsville '(C) #
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East f Berim \ /
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3.3 Serious Health Effects Beyond 10 Miles Acknowledged By GPU's Pavout of Nearly 4 Million Dullars On February 7,.1985, a Dauphin County judge approved awards of nearly four million dollars to persons claiming they "most probably came into physical contact with some radioactive debris" which"was dispersed throughout a large area." See Exhibit 2 attached.
Information concerning the exact nature of the injuries claimed was not provided (except in the case of a Downs Syndrome case) because GPU required silence on the part, of the claimants in return for the out-of-court settlements. Except for thirteen claimants, the addresses were not provided. Of those, seven residences are outside 10 mile radius of TMI. Seven live in Mt. .loy and Columbia, southeast of TMI, and one in Harrisburg, northwest of TMI, the two general directions where the majority of the serious cases plotted in Figure 3 also reside.
, Additional confirmation of plume impact in these directions is provided by the door-to-door survey results reported in the Aamodt motion (two areas were west northwest of TM()and " clusters" such as the one reported in Maytown. See Exhibit 3- attached.
The juvenile cases came to notice of the press because they required approval of the court. GPU has admitted that "300 personal injury claims" were being settled out of cour,t> essentially an admission of guilt and unethical silencing of the accuser.
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4.0 Evidence of Radiation From TMI Presently in Environment 4.1 Measurements West of TMI By Agencies On August 15, 1985, during a meeting with the Commission, we reported that we ineasured radiation on top of the ground ten times air level. west of TMI.
(The instrument used was a Victorinne handheld owned by a local resident). ,
This measurement was checked by use of the Newberry Township meter (also a Victorinne). The results obtained were the same (0.lmr. gamma).
These readings were made in May 1984. Subscquently, on August 30, 1984, I at the request of William Travers of the NRC field office in Middletown, PA, we arranged for representatives of NRC, DER and EPA to take measurements (onsite), and soil and water for sampling. On October 31, 1984, the NRC issued a joint report for the agencies which stated that there were no abnormal indications, however further analyses were underway and would be reported when completed. Approximately eight months after taking samples and more than a month after our reminder, the EPA issued a joint report on February 25,1985. The NRC director had indicated that the delay in the final report was due to roulninns being made to the data by the director of the EPA field office in Middletown, Dr. William Kirk. We requested the original results and an explanation of any " revisions", however a single report was provided.
We have reason to suspect that the surveillance done by the agencies was not adequate, if honest. hie continue to receive reports from a resident where samples were taken who is experiencing health offects similar to those experienced at the time of the accident (see Affidavit 1 of Aamodt Motion, June 21, 1984) but not quite as severe. Other persons in this neighborhood are continuing to experience effects that are of the kind j produced by high doses of radiation. For instance, the resident (referenced above) experiences tearing and burning eyes, erythema, the effect of looking through water, and blisters on and in his mouth after working outside on his
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property. His wife has experienced the same kinds of symptoms, but to a lesser degree; she is - not outside as much as her husband.
Neighbors have reported persistent and unexplained . blisters on their
- feet; several dogs in the neighborhood also have blisters on their paws.
Last fall, four men in total who were in the woods in the same area had to seek emergency treatment for swollen and blistered mouths and throats. Several residents are continuing to experience hair loss, including a young child. The resident, referenced at'ove, and his wife lost all their body hair by the end of last year. (Unlike previous years since the accident, these two persons have been engaged in extensive landscaping of their property since last May.) When ,they spent several months in Florida this past winter, their body hair started to grow back. They showed the new growth to health. physicists at the PA Bureau of Radiation Protection, who were amazed but have not been able to provide relief to the residents. Since returning, the residents are again experiencing erythema, tearing eyes and other symptoms.
We believe that these residents are experiencing effects from residual radiation from the TMI-2 accident which has seeped into the soll and is being recycled by the trees and other vegetation. Dandelion leaves, nearly three feet long, were found in this area last fall; garden vegetables were gigantic. (Stimulation is a radiation-effect.)
Cumcombers were the size of mature zuchinni squash, and tomatoes the size of cantolopes. An authority in the field of the effects of ionizing radiation in plants, Dr. James Gunckel, believes that these vegetative l effects are due to radiation presently in the environment.
It should be noted that with nearly 2000 different products that occur with uranium fission, the dozen analyses performed by the agencies 129 was far from complete. All agencies refused to test for I on the basis of cost ($150/ sample), although this measurement could provide a measure of the total radiolodine released by the accident to a particular area.
The analyses and equipment used by the agencies were unable to detect the radiation people in the TMI area are experiencing. The Comission must be concerned with the dose to these people, not to the instruments.
This matter needs resolution, prior to restart; the problem is not restricted to a family or neighborhood; residents in each of the areas surveyed door-to-door reported similar experiences, notably the recurring rashes which, invariably, they experienced after extensive out-of-ddar activities.
While the 04cncies reported the radiation levels measured as not significanti t'he following statementsfrom the EPA report (2/25/B5) are
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ttoubling:
It can be stated with great certainty, however, that the amount of radioisotopes present at the locations are quite ordinary.
Levels of natural isotopes from the uranium series, thorium series and potassium-40 tended to be to The lack of preaccident samples at the same sites precludes making absolute statements regarding the precise relative concentrations of radionuclides present preaccident and now.
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..at location #2 .. levels in the front and side yards, which had been graded and topsoil removed, were lower than in parts
' of the backyard where the original soll remained ( 4-8uR/hr vs 10-12 uR/hr).
tdhile the report attributes the above average amounts of radioactivit y to 1
naturally occurring isotopes, there are no preaccident samples or other data provided to support this assertion. Further the fact that levels were lower where topsoll had been removed (by a factor of as much as 2),
would cut against the assignment of the above average readings to background.
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in the soil A more reasonable interpretation is that radioactivjtyfafter the accident is tindce the pre-accident level. Although the absolute values, even at twice the preaccident levels may appear insignificant, the doubling of the activity of the total soil sample could indicate the presence of minute -
highly-charged particules. Since the activity being measured is a
of the type, alpher,4 single minute highly-charged particle whose energy was masked by the volume of the sample could cause the kind of biological by the TMI-arearresidents damage described /if it landed on the skin.
The EPA report dismissed the damage in dogwood trees reported by one resident, and ignore. the bulk of information provided about dead pines, pear trees and red maples. The tree damage in the areas where if not every we surveyed, west of TMI, is remarkable. Nearh/_every property suffered some tree damage folloping the IMI . accident.
S.0 New Information Concerning TMI-2 Core Temperature Only recently has the fact that the core of Unit 2 reached a temperature in excess of 5000 degrees been made public information.
This information was not considered in the restart proceeding, although it is exceedingly important relative to planning for protection of the public, in the event of a repeat performance of the TMI-2 accident and.in the interpretation of health effects experienced since the accident.
The 5100 degree temperature of the core caused elevated levels of fission products and transuranics, melted the zirconium i
cladding of the core, allowing absorption by water vapor of transuranics with subsequent escape of these materials during venting and leakage to the t environment.
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Transuranics emit a type of radiation (alpha) which was not considered during the radiation measurements and dose assessments of the accident. Huwever, a single particle, too minute to be visible and only detectable at close range with special equipment, is extremely hazardous when inhaled or ingested. Little is known about the specific biological effects of transuranics, however alpha radiation, in general, causes more severe cell damage than equal doses of either gamma or neutron activity. See Exhibit 4 attached. Thus, the most-often cited reference data for biological effects from radiation (Hiroshima, Nagasaki data) where the primary exposure was to gamma and neutron activity, cannot be used as the absolute standard for interpreting TMI-related health effects.
There is a high probability that transuranic materials escaped into the environment. GPU cannot account for between 6,000 and 22,000 pounds of core material See Exhibits. attached. The assumption that this -
material is trapped within the reactor is not too credible. When Unit 2 filters were analyzed in 1980, transuranics were found in the filters. See Exhibit 6 attached. Considering the saturated and deterioriated condicion of the filters at the time of the accident and 9/
the limitations of filter 5, it is not unreasonable to postulate that transuranics went beyond the filters. Other escape routes have been identified, and more, unidentified, probably existed.
Obviously, GPU and the NRC knew in 1980 that the core temperature had exceeded 5000 degrees and that the accident had been far more serious than they were admitting. They also knew, from the presence 9/ Deitz, " Effects of Weathering on Impregnated Charcoal Performance",
]
NRL Memorandum Report 4006, NUREG/CR-0771, May 10,1979 h
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of transuranics in the filters, that these lethal products could be in the environment, however, they failed to act to protect public health and safety.
6.0 The New Information Meets the Standards for Reopening the Hearing The new information presented in this motion, by itself, meets the tripartite test of NRC rules for reopening a hearing. The information is (1) significant, (2) safety-related, and (3) would have caused the Board to have ruled differently.
The contentions, listed in Section 7.0, need to be considered prior to restart of Unit 1.
7.0 Contentions
- 1. The recommendations for protective actions for the public and emergency workers are inadequate in view of the severity of the accident and release of transuranic materials.
- 2. Emergency planning for the 10 mile radius of TMI is not responsive to the apparent severe radiological impact from the TMI accident beyond the 10 mile radius.
- 3. The public information phamplet does not alert the public to the unique hazard from alpha particulates.
- 4. The agricultural information booklet, which specifically diminishes the risk of contamination from alpha particulates, does not provide the information or means farmers would need to protect themselves from alpha
- radiation.
- 5. Dosimetry available to measure radiation in the environment would not detect alpha-emitting products released to the environment.
- 6. The public cannot not depend on the competent and honest regulation of Unit 1 by the NRC Staff.
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- 7. The public whose health has been impacted by the TMI-2 accident
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cannot safely bear the additional radiological burden of ALARA releases from the routine operation of Unit 1 as well as the potential of additional severe exposure from incidents and accidents at Unit 1.
- 8. Present GPU management has demonstrated an improper attitude in paying-off personal injury claimants to silence them.
8.0 Discussion It is our view that the investigation of the TMI accident is about to begin. Whether the NRC will provide the forum, or the outside courts will do so, is a decision that the Commission will make in the coming weeks.
The public has reason to dispair about the administration of nuclear power by the NRC. ,Ls it uncritical enthusiasm which has allowed unsubstantiated conclusions concerning radiological dose to the public to parade as scientific conclusions.? The Commission accepted the dose assessment of the Ad Hoc Committee, in rejecting our first motion for a health study, although an independent reviewer had reported the 11,/
1 conclusions of this committee were unsubstantiated.
For the first time, we fully appreciate the concerns expressed by Dr. Gordon MacLeod, director of the Pennsylvania Department of Health if the decisions concerning at the time of the accident, when he questiongd/the protective actions for the public should besmade.by nuclear
- phy' sicists.
i y, e r. u . IN : 0 uv :I~ 1 ^* '
_10f As Low As Reasonably Achieveable M / Bayes, "A Review of Dose Assessments at Three Mile Island and Recomunendations for Future Research, August 15, 1984, A29-43.
70 MacLeod wrote:
It seemed that noone outside of professional health circles could appreciate the potential for health hazards of the TMI accident unless they saw people being carried off to hospitals vomiting from radiation sickness. ..That's the attitude that seemed to reighn among nuclear engineers and radiation health physicists throughout the accident. Some of those who protested most vehemently against the recommendation that women and children leave the area were among our own ranks within state government -- not the health department ranks -- but radiation
, health physicists and engi aspects of the accident 'grs dealing with the technical t
"Some Public Health lessons From Three Mile Island". Gordon, K. MacLeod, M.D., presented in Stockholm, Sweden, March 11, 1980.
Macteod's early call for the evacuation of mothers and children west unheeded due to the opposition of the Commonwealth's radiation 13/
physicists and nuclear engineers 7 Absent a considerat!On of the health effects in residents, the Commonwealth and the NRC will allow the nuclear l physicists and health physicists to again make inapquate decisions for the public in the event of another accident, '
4 Although the restart of Unit I has been an open issue for over f six years, the Commission cannot cave-in to pressure from special interests to restart Unit 1. The evidence presented in the Aamodt Motion of January 15, 1985 and in the present motion should alert the
. Commission to the fact that the most important issue -- the health of 4
people impacted by the Unit 2 accident -- is at stake. The Commission must tarry until the matter of the extent of damage, already caused J2/The Commonwealth's nuclear engineer replied, when asked if he IN11eved that the plant was stable after he learned about the high radiation levels, " Yeah, I guess so." NUREG-0760,103-4.pp.14.
A Commonwealth health physicist testified in the tart proceeding
' that the Bureau of Radiation Protection is in the seiness of public health...what impacts most people" and does not take unique exposures, such as the farming family into account. Tr.18,225.
J.3./ Bulletin, Allegheny County Medica,1 Society, April 26,1980, Vol. 69, No. 8, pp.157,
i i
by the TMI-2 accident, has been assessed. A little more exposure to radiation may be too much for an elderly person, a little child, or a ,
I t pregnant Amish woman. The Commission's decision will be a matter of life orl
. . f death for a presently unknown number of persons who live in the path winds! I from TMI travel.
9.0 Conclusions -
If the Co.nmission should allow the restart of Unit 1 prior to a full investigat!'on of health effects in the TMI area, the people of central Perwisylvania should call for the resignation of all consentinn Commissioners. Unless the Commissioners heed the public's outcry concerning health problems by deferring its decision on restart of Unit 1 until this matter is fully understood, the Commission will face ;
a public challenge of its own integrity. The Commissioners are, in ;
fact, engaging in criminal neglect of their duty in continuing to ignore their responsibility for the public's health and safety in the '
face of the clear evidence provided in the Aamodt Motions of June ,
June 21,1984 January 15, 1985 and this amerwjment. !
Respectfully submitted, ,
/AttL 40. Ard Norman D. Aamodt hi//tG (o M i dl) 4.LU l Marjorio M. Aamodt i i
I f
April 13,1985 I
., . . . .u i . s ga3eoj 0.5 I.0 ^' O- O'S o.i i
I l
50 t / 100 N,t, - - - C.I L
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l 5
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l Department of Energy)10-Mile Exposure Profile (mR for the Note: See discussion on instrument er d Mar 8 throuf,'i calibration on page A-5 9
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AERIAL SURYCY ,
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- Osr Harrisbury, radiation measurements in the plum ~'~ ' - ~ " ~ ~- --
.showed about 0.1 ar/hr. At.10 miles from the site.-
the plume was about 4-5 miles widei top of plume at ,
stout 3000 feet. - -
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Plume in a il to IN direction. Primarily Xe-133.
Radiation measurements in the plume at about 10 miles *
. from plant in centerline of plu:r.c were 0.2 mr/hr; at 1 mile from plant, about 0.5 mr/hr maximum. ,
3 gw,w
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EXHIBIT 1 (4 pa*ges)
- . AERIA1. SURVEY p ... .
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s .
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i N'J ' - 35 50 .
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~
i 1
~
. ~.. . . , .
3-mile skiIizabethtown T
old.sboro
' ' Island .
g y.S
.>
stemming from the 1979 accident. Marchillo Sardi, Columbia -
said Lee Swartz, one of the attor- *
.R3, said his two children. Marco neys for the youths. Corp., said in Lancaster Tuesday. Sardi,14, and Edrige Sardi,14,. {
The cash aw were approved m,ard agreements "It did not represent a decision by developed stress because of the 9 January and GPU.'
- accident. The children developed 'o-February by Dauphin County , Clark said the m.surance com- "a lot of nightmares," he said. --
Court Judge William W. Lipsitt. panies weighed the cost of the set- Each of the children received 2 The money will be paid by insur. tiements against .the expense of $30,000, y ance companies for the defan gomg to trial.The settlements are Receiving $21,700 in the settle-dants: General Public Utilities not an admission of guilt,he said. mentis AmyShoop,6 daughterof Corp., the owner of the plant, and The settlements say the chil- Edward and Sydney Shoop, Bain-litan Edison Co., the GPU dren did hot sJfer any "prov- brid e Metrobry subsi operating the plant at able" injuries froin radiation ex- hhi largest award of the 68 the time of the accident. posure or any emotional mjuries. settlements - $1.095.000 - went While the lawsuits claimed . requiring medical treatment the accident caused, birth defects caused by the accident. ,
_$,, 3 7._pp ,
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EXHIBIT 3 (2 pages) 1 (emphasis added)
A Time For SharinaU And Cctrinc u Party Brings '-
W .
7 Young Friends M[ Y.. . L 8.x.;MWR t Back Together &
a J.. ,;*. '
?.;4 c -
v.4 ( .
By Roxanne Platt NE<. ZC 3 ,i , E ExtraStaff Writer Y,l 4.l -Q.l MAYTOWN - Dey used to sit together Mj.C -
' aRl9 M ):
in the schoolyard - playing games, talking g' ,
and' spending time with each other. :
t ' . L
._ even-ye a r-old Matt hew Decker. c k
suffering from the affects of an inonernble, ;T ,. k i;~4 ' %' ' A ) h' %
benign brain tumor and the medication that f
. i
- - W.
' accompanies the treatmerits, was confined
/.h>5if,%}Z.$. /:. i'- ! ' '..N '-
to a wheelchair. !- L .
[
i Michelle Turner, a classmate of Matt's f% '
[Mkh b.- I i at Maytown Elementary School, befriended him. The Maytown girI knew that Matt was a-
~, j 5. g,s ghe u..
- i - M ~
i* h..'".~ *:
As4 j.;:-if G-
'o
.s :
i ill. lleghowever, didn't realize that she was "
'M '
' ' i .' . /:.'e'P N. Dm;.? i.WR 5 .- :
suffering from leukemin. While other class- .N t N 4: . .i E ~ h .l':i - ' ' c ,' g 3 ; .f mates ran and played durin6 recess, the :k. . Ac:
- d. .N' y
two of them grew t8be close friends. QQ./ - ~-'
- 1 ' .
- .~ J^t f '
- , . .c
%,3. : ' N 'p ,E 1
Last Hursday, Michelle turned eight- ?(; ',3: /: <
t
/.t . i ~. 4 .- ; .
. .. c. < ' 9 # J years-old and Matt, the son of James and H,.; . ' '% .9I Donna Decker, Mount Joy R2, made a guest appearance to wish her well.
- y .
i - ..Q{ . . "k
- . - . .?fg,A
- d. .- ;e ...
+ i . "y y; -c
~1
. .,Q Complete with party hats, a specially, 'J : . O^ T J, .MT created birthday cake, and oodles of %'N ge . .g,m. ; 7, .' ./. ~; * ' "y '
.. . ; S :
friends, Michelle's party was her second in 3 s -
? M 1 e- ',b .,-. %. 4 .q.,J'C , P{ .;. . . .
two days. De previous day, her first grade
' ~
- 4. s , .. . '^-
class at Maytown Elementary held a small ~ d . ., 2. -
s '
fy l celebration for her, too. i
.; ,y ENC '% .? 9 ne piece de resistance for Michelle this year was a bicycle, given to her by the dM'L A3' ' C. ~
..s . "; . . .:- 9 ;R;?'4,- g:-
entire student body of W.I. Beahm Junior i'
- We - .J ... l ' *3 E.
liigh School. De money, which was collect- .x .- 'M -
.C. --
E ed at the recent Lolli Sale at the school, . .; * *J ' d4
- ~.*1 Aj 7 7/ -c $ a1,: b'- 'g, p was donated to a fu for Michelle. The f ..". '
~
L fhnd is being handled by the Welcome -A e
g o.iW 1: . M. ,f; y(. W'\ $ ."M s,;;;:. r 1.A;' k -
h Wagon Club of Mount Joy. ;., , ' . . ,f 2"'idy:;,. p % ( [ R e :' 7 'p i n3. 7
- g 'g f . Q ', ..~
~
Cheri Dillow, a sp'okesman for the Wel- ,.?
come Wagon because it was suc said the group felt that Club,h a special time for Mi-,,.*3 n:R h; e" T
'g. :
.n
- i. 3 - . ,.j 4 " ,. f rhelle and because the funds for such a gin - ' -
A were beyond her mother's means;it would l, .WM f '
~
W be nice to use the junior high school student MM g ,.
collections to go towartl Michelle's< dream bicycle.
v, *,.
.r . <
- -h 7 .
j "ney f i l
i party at bavel,"it said (bike)'
he to her aner mother, the Shirley- l %S:M M.iNc T V ~rcl '
~ .M b5 Stoudt,'119 Maplewood Lane, Maytown. . ExTna rhawa ,6 bya.ma rs==
"Gail (Goodhart, a friend of the family) Michelle Tumer tumed eight last week and one of her friends, Matthew Dakar of carried Michelle out of the building aner school and told her to keep her eyes closed Mount Joy, showed up os a special guest. s. - 4;.j- i her," s'aki Matt. .1. g,fg p,'.1
-6 sotilthey got next to the bike. m Center, while Matt:travpis to Philadelphia 4,-
r.,
" s Chikiren's llospital for' occasional tests and "At the time;t'.Miss Stoudt said,aam
ing outside at recess te Hf c e mother ad CATscans. ' : chcIle 1rasn't
's m When Matt and Micl helle met iri Sep.' onen because . white (blood cell) coin she stopped. down the . (mber 1 , he iw a a wa She asg arr streetitaandcoupletook off, of times t ridinhfoband she dida, W."It's made her very happy and that's meNUnit 13. He remained there until sit andplay.wittihim/.% . .i .
wtpat I.want, for her to~be happy. Every. .
that December when he was placed;in an At the end of tast year; Michelle was as we go all out because we Just don't Educable Mentally Retarded (EMR) class J
at East liigh Elementary School in Eliza , ;.mitted
. ment. . tollershey : - $ 34tdicalCuriterfor
"' jir aMichelle is currently undergolng che- bethtownc -
motheras treatments at'llershey_ Medicals "Uh H em h m Whukt.We E rste t' rn~nDorisarhms
EXHIBIT 3 (2 pages) l E TRA l
Put(thed evdwy hed y by Lancaster Newspapers. Inc. s Lancaster, Pa. - March 20.1985 i
I Party Brings- ,.,W;,:. . X... :.cPU,.: Nm at.
. . . y....n . ?. ... , . .SWR.g+ r. . - .: . m?..,;
~ ~, y .~, .,..g- <
y
.w .
~m ~
~2 . . ..
Two To'gether' 9.m. ., ..;,Ma:%. W,"4:p-.m.._ s. - .. , .
C 5 , . , . . .
a M"
l - l-l .b*ll, . .
T ';
w - , . . + .. '. ' l-Continued from Page One '.: ' ' *
.. .l. C..;:Y . -.,.:..,...,;-
c ~, ;.' 3 . . '<
i J ' .f r # - a .- ':. : 'f- y r.. .-
. "I'didn't even know that they 2 :? <!lc. . . ' f' ,l knew each other until I saw a : c' ' ' M . :: J~. ..,:.f,:1-['. . M' :
.*J 't; . $ ' . .J . ?? .. ' . . ' '
story in the newspaper about her P
~
- J. -f l being in the hospital," Mrs; Deck , .. . . .F ' ')
- 1g '
C " ~- -)', .
er said. "Mrs. ,(BrendaEImpley..; . .*D ' < c ^ .- . > . <qe'. 4 " . *V ' . ..
Matt's former teacher, told me." + .' J' ' '
'c . .: -
.1~'
ff -. .
- 3? . J "- / l
- -
In January, Matt and his ;. .. ' :.".M .
mother went to llershey to visit
. ..P : y .- l J.. ., '? ...q :
Michelle. .
- .27.o~- :..f.,,..
' -EJ ; . ., 4
-/....*
r I
"I went because I wanted to 7.2 2 V.'.h "
.. 4%' D. :
.'fi.i !
. see her," he said. He ted C r. :
- y' - ?.W i
- y her with a red rose on visit. ?; r '3 ' ll' ; :i!". . "4 "I thought she'd never remember' 9.. ' .v J 3:' y 'i ' "
me when I went to the hosystal to
-f; : f a 'J [AN
. ... <:1 2.'-Q. S .. , ..
see her because I got glasses." ~ -' <. % 't 1'> 6 'N.^
- D .;Ji.;' NJ 5
- ::L
r "She got lum back." Mi- e =
. 'l '
chelle's mother said. "Since he had seen her at school, she got a ' p$ j %'
'N_ # QJr' . d M .(.: 6... '
~~
--A25.'.'.'.E..'pf.
wig." .
Both of the youngsters. liad
(
.p.'fQ??
,{ .
gmpy.;. dl9 .HTT ; ::. -l '.' =, . %.o gl;.;..Q g
";hy;p i
^.e, . ~::
lost weight, too. Matt lost 17 4 .r<-
'?g i.a . " / ' .
pounds: Michelle,12. i .g W;f P. r ?.2'd.il.i s)i:f; 4 .h.. *rr-' V . :.tN.c',%
.,1 f ';
"Everytime I saw her," he .N ' Y +. 9 %
. .lc e ?/ 7 c. ' ~ O lf. * "c.J0' '.6;14 said,"she looked difTerent." .
.'-l$v . .2. 9 ? O ' "J.l-Matt and his family made a Z/ -- C ' -i..(f
. c. ? .& : J c.E.* O 1. E . ' . - '> ,
second trip to see Michelle at the hospital but were surprised to find-l T. ' 2.N-E p<? *b.J6 7.G.C" . %::,,,U$% ..:
. ; )y ' . .c:, ,
c.j ! .12 5
~
t e ^ i c. 4 '-
JM.p: . i. % 4: ';.::+,23 pJ ( p* Z *. : J W.1. :". /.Fc her room door closed. ? j;.
"We asked the nurse," Ikatt ' 'f J
- Y . dY.I ' ./$'Q,;.gs? .i'- MO ' ' i.f.f L .7 '?
recalled, "and she said that Mi- [/ . .u a ! < *
./ T. P.
f' + "(? "; W Ocl.t.:i'd f.
.*p;U. 'M0:9 chelle went home." L . :
"We must have paessd them s -: i c .cd.; '.M;s.
on different elevators or-some- -
j.c4*%
M,3 p, n .. J ~. .g. 7 3 .; . . a thing," said Mrs.Deckerc "The
}f 5 s ./; @ '.y'w ??
4 . jf:. M .;..>;;;
Y J .';'h ' -
b.:- .
so much,y've " said both Miss been Stoudt, . <
yl ;//h '" ..:4;-;1 feels that their' friendship is an - ' *$J$p. 0;';I:.. .' .]Q.; - P.' .M. .
- e. - f ,..
M ~p@8A' .. "y%. K 3'f. 6 0.( ^ . ;, -::T gb
. importantunderstandingtool j ' - - "'-
N,-
Sometimes they're comfort..
able talkifig and othertimes, they ,, c ,. .* Mm w by as - Man justlike gitt together.It's good ' Pmeeeds from e tellip.p Day sols e, &whndonierHigh 5 9hooO ror them to be .r n, a ,h. pu,ch.e. .f . bicycs. for M.cheiws birthdoi.' i
EXHIBIT 4 (3 pages) , 4 j.
.j
, .3 THE DEPOSITION OF RADIANT ENERGY j ,s, When ionizing radiations deposit energy in biological materials, !
ionizations and excitations occur which are not by any means dis-tributed at random. The events tend to be localized along the tracks of 43 -
individual ionizag particles, in a pattern dependent upon the type of i !
radiation involved. For example, photons of x rays give rise to fast elec-
Q ,.
trons, particles carrying unit electric charge and having very small %
mass; neutrons, on the other hand, give rise to recoil protons, particles V'Q again carrying unit electric charge but this time the particles have a M mass nearly 2000 times greater than that of the election. Alpha partit gq cles ionize directly; since they are helium nuclei they carry two electric _
bg
) -
charges on a particle four times as heavy as a proton, and therefore al- ,
most 8000 times as heavy as an electron. - - 'G i{ Q ,
These various charged particles have very different charge-to-mass
f ratios, as well as different velocities, and as a result the spatial distribu-
'e tion of the ionizing events they produce will differ markedly. The aver-age separation of primary events along a track of an ionizmg particle i
)i* decreases with increasing charge and mass. The tracks of energetic elec-
' trons, produced by the absorption of x-ray photons, will be traced by Individual primary events which are well separated in space; hence
- x rays are usually described as being sparsely ionizing. At the other ex-
- treme, a particles (which are slow moving, heavy, and cumbersome by comparison with electrons) give rise to individual ionizing events which occur so close together that they tend to overlap, giving rise to tracks
) which consist of well delineated columns of ionization. Alpha particles.
I therefore, are,saidlo_h3 denselv ionizinr< Neutrons fall between these two extremes, and are consequently referred to as particles of intermedi-3 ate ionizing density.
LINEAR ENERGY TRANSFER (1.ET)
% h.- -norev +cancfer n im is a term introduced by Zirkle, and is the enerry transferred eer unit length of the track. The unit usually used for this quantity is kev per micron of unit density material. The International Commission of Radiological Units (1962) defined this quantity as follows:
The linear enesgy transfer (L) of charged particles in a medium is the quo-tient of dE/di, where dE is the average energy locally imparted to the medium by a charged particle of specified energy in traversing a distance of di.
l LET and RBE / 65
----W"=' ---.----.m ,_ , , _____
T -
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'w S 's, 4
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' ' ' ' ' ' 'm' ' ' ' '
o sso soo rso ioco itso isoo irso 10-4 oose per reaction or fasi neutrons trads) 0 2 4 6 8 0 2 l 71gure 4-2. RBE for normal tissues irradiated with neutrons froin the DOSE IN RADS X 100 Hammersmith Cyclotron as a function of dose per fraction of fast Tip n Swd - 6 e s e d be e n W m neutrons. H: human skin reactions, P: pig skin reactions, G: 4-day gut x V W h M
' de th in mice,4: leakage of protem, from mouse gut, A: leakage of the radiation increases the slope of the survival curves gets steeper and Libumin from rat gut, B: stunting of tall growth in rats, K: observation the size of the initial shoulder gets smaller. (Redrawn from Broerse JJ, cf clones in rat bones, E: survival of chick embryos, R: rat skin Barendsen GW, van Kersen GR: Int J Radiat Biol 13: 559-572,1967 reactions, SR: rat skin reactions, M: mouse skin reactions, C: clones in and Barendsen GW: in Current Topics in Radiation Research. Ebert M, mouse skin, t: weight loss in mouse testes, Y: mouse lymphocytes, H ward A, Eds. Amsterdam, North-Holland Publishing Co.,1968, Vol 4, I TH: weight loss in mouse thymus, Sp: mouse hemopoietic ce!!s, spleen pP 273-356.
! colony assay, D: 30-day death in mice. (From Field SB: Radio! 93: 915, 1969.)
unity, that is, the shoulder of the curve becomes progressively smaller as the LET increases. A more common way to represent these data is to
! It is important to realize that the RBE of a densely ionizing radiation plot the RBE as a function of LET; this has been done in Figure 4-4. As does not have a unique value. It may vary due to several factors, in par- the LET increases the RBE increases slowly at first, and then rnore ticular the size of the dose fraction. This consideration has important rapidly as the LET increases beyond 10 kev /g. Between 10 and 100 E implications in the planning of radiotherapy schedules with new and un. kev / the RBE increases rapidly with increasing LET, and in fact 5 conventional radiation modalities. reaches a maximum at about 100 kev / ; beyond this value for the LET, 5 H
the RBE again falls to lower values. This is an important effect and #
RBE AS A FUNCTION OF LET ' needs to be explained in more detail.
i Figura 4-3 illustrates the survival curves obtained for x rays, for 14- o M:V neutrons, and for a particles. As the LET increases from about 2 THE " OVERKILL" EFFECT k:V/p, for x rays, up to 100 kev /p, for a particles, the survival curve As described in a previous section, the shape of the survival curve for 3 changes in two important respects. Firstly, the slope of the survival mammalian cells exposed to a sparsely ionizing radiation, such as x rays,
- curva increases, and secondly the extrapolation number tends towards LET and RBE / 71 70 / Radiobiology for the Radiologist
Lun oramat um LET
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Figure 4-4. The variation of RBE with LET for survival of mammalian cells of human origin. The RBE rises to a maximum at an LET of about 100 kev /p, and subsequently falls for higher values of LET. Curves 1, 2 and 3 refer to cell survival levels of 0.8,0.1, and 0.01, respectively, illustrating that the absolute value of the RBE is not unique, but depends on the level of biological damage, and therefore on the dose level. (From '
Barendsen GW: in Current Topics in Radiation Research. Ebert M, LET Howard A, Eds. Amsterdam, North-Holland Publishing Co.,1968, Vol 4, '
pP 293-356.) Figure 4-5. Diagrammatic representation of " overkill." For a cell to be killed, energy must be deposited in a number of critical sites within the cell. ,
Sparsely lonizing radiation is inefficient because more than one particle -!
str:ngly indicates that there is more than one target within the cell in must pass through the cell in order to kill it. Very densely ionizing radiation is also inefficient because it deposits more than enough energy &
which energy must be deposited before the cell will lose its reproductive .
in the critical sites within the cell; energy is wasted, the cells are I
integrity. In the case of x or y rays, ionizing events along the tracks of "overkilled." Radiation of optimum LET deposits just enough energy to %
chirged particles are separated by relatively long intervals, and indeed inactivate the critical targets. -
o it is for this reason that they are described as sparsely Iom. .zmg.On i cv; rage, the spacing between ionizing events is such that it is extremely j unlikely that more than one such event will occur within the sensitive integrity; but it must be emphasized that the same argument will applyi t:rget volume of the cell due to the passage of a single electron gener- in the general case where there are n sites, and there is no informatiord j tted by an x-ray photon. In general, for a cell to be killed by sparsely concerning the actual number of sites that must be damaged within the l linizing radiations, events must occur within the cell from more than cell. In Figure 4-5, sparsely ionizing radiation, such as x rays, is de-one electron passing through it. picted as being of low LET: the ionizing events are widely separated, l and in most cases only one ionizing event will be deposited per cell, i In Figure 4-5, cells are depicted as having two sensitive sites in which which is insufficient to cause that cell to lose its reproductive capacity.
energy must be deposited in aider for the cell to lose its reproductive 72 / Radiobiology for the Radiologist LET and RBE / 73
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Percent Core Region Pouncs (250.000/fotat) 64-92 teactor vessel Bottoa 235.000-257.000 6-14 11.000-39.000 Outside Reactor vessel 26 j
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$40 Q 21 2g DAV/bc 1 We believe about two-thirds of that is et the 2 bottom of the reactor ve ssel, probably on r en ul ar mat er ial .
3 fes we see on top of the rubble bed at the present time. The 4 _
balance -is in the primary system, probably mostly in the 5
seam and generators and most parts of the primary piping. .
6 Af ter fuel removal from the core region is 7
comple ted , th'at's about a year af ter we start next July, a there'll be p.ertial disassembly of the core s .pport 9 . structure. This will permit access witih a vacuum system 10 in to the outboard and lower sections of the core suoport s
11 structure; the, lower reactor vessel had to remove the fu e'l 12 particles accumulated in those locations.
13 We're still investigating me thods for removing 14 , fuel f rom the balance of the reactor core system. Several 15 aoproaches have been considered, including local vacuuming l 16 and flushing back .into the reactor vessel itself, where l 17 vacuuming could be accomplished there.
. Id We expect to fill about 250 fuel cannist.ers in 19 ' thy process.
de now have in effect the contract be tw een, 20 GPU Nuclear and the Department of Energy, f or them to take 21 taese fuel cannisters, take custody of them at the TMI-2 '
s 22 site, ship them in a caste which they are currently 23 procuring to the - Idaho DC; site for long-term storage.
24 CiAI.9M AN PALIADI!!O Have these cannisters been 25 designed and constructed? -
\ .
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E2HIBIT 5 (3 prgss)
M40 12 27 h DAybw I . .ve're currently determining how much fuel was tr ansmi tted from the core region and deposited in other parts of the 2
.-~~ l 3 system, as shown in Figure 15. There's a small table at the !
4 bo ttom of that figure that is our. best estimate of the !
. 5 amount of material that is in the thr ee locations: the core 6 , region, the bottom of the reactor vessel .and 'the primary -
7 systems outside the reactor vessel. We now estimate that S between a percent and I6 percent on a weight basis of the 9 fuel was . transported f rom the core region.
10 Remember Ed mentioned a quick look indicated tha t 11 abou t 30 percent of the volume was missing, but we found 12 compaction below that, so on a weight ba s i s , it's somewhere IJ between a and 16 percent that is no longer in the core 14 region.
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The Philadelphia Inquirer 7 I l
==
kccident without an end -
The plutonium incident i
'Ihe job moved smoothly, at first. No tests were done to determine the pres-It was early morning, April 15,1980, and ence of plutonium particles or other fission
- workers inside the fuel-handling building products that give off a type of radiation called were transferring a highly contaminated filter ! alpha. Substances that give off alpha particles
- into a shipping cask. '
can be deadly if inhaled.
l The workers had taken the filter from the The company report shows that none of the I plant's purification system - which removes workers underwent fecal analysis, a test used radioactive fission products from the reactor's to determine whether radioactive particles cooling system - and had placed it in a special have become lodged inside the body.
canister. It was the first time that such a filter Consequently, nobody knows exactly how had been removed since the accident. mt;ch plutonium lloutz and Williams inhaled.
A crane was used to hoist the canister to the Ilildebrand, who conducted the investiga-top of the shipping cask, which was 6 feet tall tion and wrote the company report on the
, and 6 feet in diameter.The canister had a trap contamination incident, said neither lloutz door at the bottom. The plan was to open the nor Williams was wearing a respirator or pro-trap door, allowing the filter to simply slide tective clothing on the job because no one had anticipated that there would be a spread of ut o gt N C records and inter- contamination during the filter transfer.
, views with workers, the operation hit a snag.' llis repo-t concludhi that radiological con-When the door was pulled open, the filter did trols on the job had been poor, that all the not drop all the way out, and it was jammed,, workers should have worn respirators and Mike Williams, a health physics foreman, said that Houtz and Williams should have under-analyses to test for internal co e fIe t with radioactive sludge, [$f was left dangling from the bottom of the canis- i Hildebrand also concluded that the utility ter. Eventually, the workers were able to force had waited too long to investigate the incident, the filter to drop. But in the process radioac- since a June 1980 analysis of a sample taken l tive particles were jarred loose, and they from the filter had " clearly indicated the pres-l spread through the air. ence"of plutonium along with uranium, amer.
Within minutes, radiation alarms sau'aded it'ium c and other materials that give off alpha and contamination was detected on a worker. '
The building was evacuated. (radiation.Hildebrand concluded, howev'er, that th/
By the time the night was through, six more amount of plutonium inhaled by floutz and workers would be contaminated. Williams was a minute fraction of the allowa-
- George lloutz, a health-physics technician ble limits set by the NRC. lie said during an who took part in the operation, said during an interview that the incident was "not signifi-interview,"To make a long story short,I guess cant."
it just got away from us." During interviews, Johnson and Gofman l What floutz and the other workers did not said the incident did not appear insignificant know at the time was that the filter they were at all.
transporting was contaminated by radioactive " Plutonium is the most hazardous substance plutonium, which had escaped from the reac- of commercial importance known to man,"
tor core during the accident. Plutonium, a said Johnson, who has studied health prob-product of nuclear fission,is one of the deadli- lems among people who were exposed to pluto-est substances on carth. nium and other radioactive materials near the They would not learn of the plutonium for Rocky Flats weapons plant in Colorado. "There more than a year. definitely is a risk to the workers."
It was not until April 1981, after another And Gofman, former associate director of spread of contamination, that an investigation the Lawrence Ilvermors Laboratory, said l of the 1980 incident was begun.That investiga- workers could develop cancer even if they
! tion concluded in May 1981 that two workers- inhaled far less plutoniu;A than the federal floutz and Williams - had inhaled plutonium government allowed.
1
., Particles. Gofman said it was impossible to say there '
l Scientists say inhaling even tiny amounts of. were no health risks because no one really l plutonium may cause cancer of the lungs. knew how much plutonium the workers had liver, bones or the lymphatic system.
been exposed to. .
An internal company report documents that
! the company's initial review of the contamina- -
l tion incident did not consider the possibility that the workers might have been exposed to plutonium.
T s
200 North Church Street (Oak 203) D %* ,[
Parkesburg,: Pennsylvania 19365 April 13, 1985 ,geg g j6 $ 143 Commissioners 1717 "H" Street, N.W.
Nuclear Regulatory Commission pg pf{-(,'h i 00CA:.gsh[cq)
Washington, D.C. 20555 -'
Dear Sirs:
On March 14, 1985, I notified you that we planned to present additional information that challenges the emergency pla'nning for the public. Although we promised the information within ten days, the job has taken a longer time.
In assembling the materials for the enclosed amendment, other new information, principally the core temperature at the time of the accident and the tons of missing core material, received our consideration in terms of what people have suffered in health ef fects.
In the interim, we were asked to testify before the Suf folk County (Long Island) legislature about the health effects at Three Mile Island. That transcript is being prepared and will be provided to the Commission as soon as it is ready. All seven legislators present for the hearing have endorsed our presentation and have avowed to pursue the TMI health problems in their considerations concerning the operation of the Shoreham. plant.
The intervenor group, TMIA, has received hundreds of calls from people who have experienced serious health problems, and they have been soliciting information. TMIA is assembling the material it has received. In addition, several citizen groups are planning or have health surveys underway. It is unfortunate that citizens have to continue to undertake the work that the NRC should have done.
, Since our telephone number is in a different area than the immediate TMI area, and it is not listed, people with problems l they wish to relate have had difficulty in reaching us. We are l amazed that a number have persisted in contacting us. As the Commission may be aware, we have left our farm, principally because we felt that our investment and lives were at risk in view of the debacle of the cleanup of Unit 2. We also found, from our intervention in the Unit 1 proceeding, that there is no dependable regulation of the many nuclear plants that are within 25 miles of the farm.
The TMI accident has greatly interrupted and changed our lives, as it has those of thousands of other people. In the event that the Commissioners have been unable to appreciate that fact in reading the affidavits provided with our motions, we are planning to send to each conunissioner a taperecording of a human experience with a plume from Unit 2 on Friday evening, March 30,1979. and of l
J
r- 3
/
the subsequent physical and emotional suffering.
Thousands of people will be affected by your decision, both physically and psychologically. You must consider the restart of Unit 1 in the most personal terms. I am sure that you would not be satisfied to reside, with your families, on the west shore of the Susquehanna River, near TMI, where people are still experiencing radiation effects and watch the steam from Unit I where the tubes are in such poor condition that the terms " quality control, quality assurance" (as developed at the Bell Telephone Laboratories) are words taken in vain.
In fact the very condition of the tubes which has become the primary problem in returning the plant to operation is one that formed the basis for a contention (Joint Intervenors) that was rejected by the Licensing Board. While the restart proceeding has failed, a reopening (as suggested by Senator Specter, before the Commission with full eight hour days of hearing) could provide the most appropriate investigation of the TMI-2 accident, through the consideration of health ef fects, and the best appreciation of the impact restart of Unit I would have on the area.
We have used increasingly strong language in our approximately 200 filings with the NRC since we began our intervention in 1979.
We abhor stridency, however the inaction and disregard of the NRC, as a regulatory and responsible body, has generated it in us and the public. If anything can be said about the people of the TMI area prior to the accident, it is that our communications were reserved.
That is not the case, now.
In concluding our amendment, we have challenged the personal integrity of each commissioner concerning his inaction and future decisions in resolving the matter of serious health effects from the TMI accident. We intend no personal of fense, or prejudgmentt of future actions, however we are serious in describing what we believe is an appropriate course of action. It is already late. Many people have died. Manymore,whocouldfhppropriatelyadvised,willdie if the Commission continues to ignore the evident severe health l ef fects caused by the TFE-2 accident.
l l Sincerely yours, btl1A 0ll
~
4!
- Ifl4 Marjofie M. Aamodt i
This is to certify that the document AMENDMENT TO AAMODT MOTION g W ETED
~ y""
OF JANUARY 15, 1985 was served on the Commission and the following 011, First Class Service List by deposit in U.S. the#13th day o% prilq g5.g g
/ t -
I ik 1< M1 Marjorie M'. Aamodt E0'Ch Tih 3 7 d fyj'
?RA NC*l SERVICE LIST Nunzio J. Palladino, Chairman Ellyn R. Weiss, Esq.
U.S. Nuclear Regulatory Commission ,
Hannon, Weiss & Jordan Washington, D. C. 20555 2001 S Street, N.W.#430 Washington, D. C. 20009 Thomas M. Roberts, Commissioner -
U.S. Nuclear Regulatory Commission Thomas Y. Au, Esq.
Washington, D. C. 20555 Office of Chief Counsel Department of Environmental James K. Asselstine, Commissioner Resources U.S. Nuclear Regulatory Commission 505 Executive House Washington, D. C. 20555 P.O. Box 2357 Harrisburg, PA 17120 Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission George F. Trowbridge, Esq.
Washington, D. C. 20555 Shaw, Pittman, Potts &
Trowbridge Lando W. Zeck, Jrl., Commissioner U.S. Nuclear Regulatory Consnission 1800 M Street NW Washington, D. C. 20036 Washington, D. C. 20555 Atomic Safety and Licensing Board Three Mile Island Alert 315 Maclay Street U.S. Nuclear Regulatory Commission Harrisburg, PA -
Washington, D. C. 20555 Tom Devine. Esq.
(
Atomic Safety and Licensing Government Accountability j . Appeal Board Project U.S. Nuclear Regulatory Conunission Washington, D. C. 20555 1555 Connecticut Avenue Washington, D. C. 20036 Docketing and Service Section (3)
Office of the Secretary U.S. Nuclear Regulatory Conunission Washington, D. C. 20555 c
I l
MarVE. Wagner, Esq.
U.S. Nuclear Regulatory Staff U.S. Nuclear Regulatory Commission l Washington, D. C. 20555 t J