Three Mile Island Alert 20th Anniversary Press Packet

Enclosed please find information pertaining to Three Mile Island (TMI), nuclear power, and the experiences of local residents in dealing with both. Please note that all the data contained in this packet has been thoroughly researched, documented, and based on factual data. If you need to verify any of it, don't hesitate to ask.

The 20th anniversary of the beginning of the accident comes in the early stages of deregulation of the electric business here in Pennsylvania. Electrical generation confronts a new era of challenges emanating from this deregulation, corporate consolidation, and the decontamination and decommissioning of aging reactors. We strongly believe that economic pressures embedded in a competitive market will force nuclear plant operators to "cut back," "streamline," "downsize," and relegate safety and public health concerns to a corporate footnote.

We look forward to meeting with as many as you as possible. Please bear in mind that our staff is composed of volunteers who work full-time, parent, and live in the immediate community. We understand that for many of you, this will be the first time that you have visited the area to report on TMI. We encourage you to familiarize yourself with the materials provided.

The accident at TMI did not end in early April 1979. TMI continues to haunt area residents who have struggled to reclaim their lives. Many of our colleagues have retired, passed away, or relocated. The same phenomena has affected the press corps. We ask that you be respectful, courteous, and honest with area residents. It may be hard for many of you to comprehend, but we strongly believe the owners and operators of Three Mile Island got away with murder. Twenty years after the accident, we are still waiting for our day in court.

Though this is an emotional and volatile issue, we have worked hard to make these documents factual and verifiable. Please feel free to contact TMIA if we can be of any assistance to you.

Sincerely,

The TMI-Alert Planning Council

Litigation: 20 Years Later The Lawsuits Continue

Currently there are pending personal injury lawsuits for over 2,000 plaintiffs which are in appeal of a Summary Judgment filed by defendants Met-Ed, et al. Once again, the controlling hands of Federal District Judge Sylvia Rambo threw out most of the plaintiffs' expert witnesses, as she decided the issues of fact that belong instead before a jury. Twenty years later, people harmed by the nuclear accident are still waiting for their day in court.

In 1985, Met-Ed's insurance pool paid more than $3.9 million dollars for out-of-court settlements of personal injury lawsuits, many involving children. The largest settlement, over one million dollars, was for a child born with Down's Syndrome. State law requires certain legal matters involving children to be made public; had it not been for the children's settlements, we may never have learned of this or other cases settled because stipulations incorporated into the settlement agreements prohibited plaintiffs from discussing their settlements. Funds from the $560 billion dollars Price-Anderson Act insurance pool paid these settlements. More cases are pending, such as the actions filed by a group of veterinarians and by the tourism industry, but these matters must await the outcome of the personal injury cases. Any moneys left over may then be applied to settle the remaining cases.

Lawsuits not involving personal injury, such as the class action for property loss, evacuation losses and expenses for individuals, corporations and governmental agencies and municipalities were settled some time ago. In 1982, after Judge Rambo dismissed two suits seeking reimbursement for costs of emergency services provided during the accident, the U.S. Circuit Court of Appeals reinstated the cases which resulted in settlements of $250,000 to the Commonwealth of Pennsylvania and $225,000 to the municipalities. "Temporary evacuation, which lasted less than two weeks for most evacuees, caused short term economic loss of approximately $90 million dollars to individuals and local communities."

To date, public records show GPU and the nuclear industry has paid out at least $50 million to plaintiffs from TMI-related suits brought against them.

Three Mile Island's Health Effects: Two Decades of Deceit

The most fundamental and critical issues surrounding the accident at Three Mile Island are the adverse health effects and the unresolved questions of dose. The facts are that people have experienced radiation symptoms and have suffered adverse health effects. Some have died and more will as a result of the accident .

Unfortunately, the lie that not enough radiation was released to cause harm has been told so often by the Nuclear Regulatory Commission, GPU, and others, it has become part of the "official science." Many of us, as "human dosimeters," unaware of the accident, reported radiation symptoms during the accident, but the authorities responsible for protecting our health and safety refused to look into our allegations. The NRC omitted evidence of dose limit violations and they never fined TMI's owner Metropolitan Edison (Met-Ed) for overdosing the public. All of the critical radiation monitors at the plant went off-scale during the accident. The authorities, however, misrepresented one radiation monitor as having remained "on-scale" during the accident when it did not. And they shamelessly prohibited conclusions of any health damage, when in fact there are.

What We Know

There is no doubt adverse health effects occurred as a result of the accident at Three Mile Island. A recently published study by Dr. Steve Wing of the University of North Carolina has verified increased cancer incidence around TMI. Wing also states in his re-analysis of the Columbia University study, that Columbia found positive results but interpreted them as negative. In fact, studies conducted by Columbia and the Pennsylvania Department of Health have shown increases in adverse pregnancy outcomes as well as cancers, despite their conclusions to the contrary.

We have found that official studies pertaining to the TMI nuclear accident are intentionally misleading reports funded in whole or in part by state and federal governments, Met-Ed/GPU, and the nuclear industry. Even Columbia University's Study was paid via the TMI Public Health Fund and needed approval by federal Judge Sylvia Rambo and Met-Ed's lawyers. Their "official scientists" will tell you TMI did not cause adverse pregnancy outcomes or cancer increases because "not enough radiation escaped." They might tell you there were increases in some health effects caused by stress; smoking, drinking or taking tranquilizers; population increases; or due to radon or some other environmental problem. The fact is their scientists falsely concluded radiation doses were too low to cause any harm, and thereby, completely exonerated TMI as the cause.

The facts are that people of Three Mile Island have suffered adverse health effects. Some of us have died. More will in the future as a result of the radioactive releases from the accident.

The Question of Dose: Different Answers All Around

Since the accident at TMI, the people of central Pennsylvania have lived with a paradox. Official dose estimates during and immediately following the accident state that it was to low to cause us to experience any symptoms from being exposed to radiation. However, we experienced symptoms. Does this mean the dose was higher than official estimates? Or does this mean it takes smaller doses than previously estimated to cause the symptoms we experienced?

For those of us who live here, the legacy of TMI is obfuscation, scientific fraud, and the miscarriage of justice. To this day, the answer to how much radiation got out and what exposures we received depends on who is asked the question. No one knows definitely how much radiation was released.

Following the accident, town meetings were held throughout central Pennsylvania to let citizens ask questions and vent their feelings. As concerned, intelligent lay people, we had requested raw data pertaining to various dose and health issues. We were rebuffed, refused, or asked to pay outrageous sums for this information. The scientific community proffered "official" documents to placate us, but we found they contained discrepancies, misrepresentations, and contradictions. Our questions have persisted because many of us had the symptoms of radiation exposure or know people who did.

For decades it was the official policy of our government to withhold the truth about radiation exposure in the name of national security. We were the first people to suffer atomic bomb fallout as the government, through its early atomic weapons tests, bombed its own people. In that same tradition, the government has yet to acknowledge that the radiation monitor used to "extrapolate" the stack release of radioactivity at TMI, did not remain on scale during the accident as their scientists have led the world to believe. All monitors went off scale high.

To this day, we in central Pennsylvania continue to seek answers regarding how much radiation was actually released during the accident and its aftermath. There is no proof that the nuclear industry's 13 to 20 million curies of noble radioactive gasses released during the days and weeks of the accident was harmless, we know the opposite to be true. Add to this the venting of more than 100,000 curies of krypton and other radionuclides from the containment building in 1980, and add (since radiation damage is cumulative) the releases from the clean-up, as well as the Unit 1 routine and accidental releases, and it becomes clear that we have been bombarded with an enormous amount of radiation from TMI.

The people of central Pennsylvania have experienced and documented the respiratory problems, the metallic taste, and the reddened skin during the accident. It is we the people of central Pennsylvania who report increased incidence of cancer, who find mutated vegetation in their gardens and yards, and mutated animals on their farms. But twenty years after the accident, neither the government nor the nuclear industry admits that a human, an animal, or even a flower has been harmed as a result of the Three Mile Island accident.

The Accident Continues: Individual Stories from TMI

Symptoms reported during the accident were very real. Thousands of people called the Governor's hot-line and TMIA's telephone log listed a full range of radiation symptoms. The burning or irritation of the eyes, nose and throat, reddening of the skin, breathing difficulties, headaches, joint aches, menstrual irregularities, as well as nausea, vomiting, diarrhea, hair loss were the precursors of the nightmare to come. A letter by Harrisburg Mayor Stephen Reed, then a member of the State House of Representatives, asked the NRC why it had refused to examine these effects. The NRC's Harold Denton issued the now classic response which is still echoed today - not enough radiation escaped to cause any of the symptoms.

Living on the west bank of the Susquehanna River, Bill Whittock was startled by the roar of the steam blowing out of TMI around 4:00 a.m. Bill remembers the metallic taste, and developed skin cancer. Now his wife has breast cancer. They are plaintiffs in the consolidated personal injury lawsuit currently on appeal.

While preparing to milk the cows, Marie Holowka of Zions View, was engulfed by strange blue air, began choking and could barely breathe. She fell to the ground and was sick for days. Many of her cows died after the accident and the Guinea fowl eggs would not hatch. Marie developed a thyroid problem, breast cancer, and later cancer around her heart. Marie has died and her case is pending.

Louise Hardison had many problems after the accident. Goats, chickens, cats and rabbits died on her farm across the road from TMI. Stillborn lambs and some rabbits were deformed - they were missing some of their legs. Louise has also died. Her farm was sold and now mutated dandelions still grow in the unused pasture.

On a hill eight miles northwest of TMI, two dentists found that all of the dental X-rays taken of their patients' teeth those first two days of the accident were fogged or banded. Radiation causes damage to film. They attached new film onto the front door for the next week and found nothing wrong with those - so they concluded they got their highest doses on the first two days.

Ruth and Clair Hoover both had the metallic taste in their mouths, they saw "white fallout" and had little red spots on their arms. After the accident they lost seven cows and 12 calves, their St. Bernard and their pony. Ruth developed reproductive problems and Clair was diagnosed with an inoperable brain tumor. They had already received settlement in the first round of lawsuits in 1985, prior to Clair's diagnosis of the brain tumor. Ruth's problems appeared to be similar to the reproductive problems in their cattle.

Fran Cain, who still lives across the river from the cooling towers at TMI experienced the metallic taste. Later that year, a poodle puppy was born with no eyes. She received a settlement in the first lawsuit.

Darla & Bill Peters had that bitter metallic taste so strong they couldn't drink enough water to get rid of it. They had burned skin and noses, and Bill got blisters on his nose and lips. Their dog and cats and kittens died. Later he found enough dead birds to fill a tractor's hydraulic bucket half full of dead birds. Bill died during his deposition for the lawsuit. One of the attorneys said, "It's OK, because we still have Darla."

Charlie Conley's cows died, the hop toads disappeared, as did the bumble bees that pollinated his clover. The cooling tower drift from the plant would hang over his trees and at times the leaves would turn black - desiccated. Many trees just died.

On Herb Myers' farm in New Cumberland, the sheep would not dilate during birthing. Some time later a stillborn double-headed calf was born and the vet told Herb to have it stuffed and mounted, which he did. Herb died of thyroid cancer shortly after the 10th anniversary of the accident. His family did not sue.

"A wave of hot air" engulfed Jean Trimmer as she leaned over her porch railing calling for her cat Shortly thereafter, her skin tingled and started to itch and later her skin appeared reddened "like after a week at the beach." She got tiny white bumps on her skin and her beautiful black hair started falling out. When her hair grew back, it had white hairs growing in a salt and pepper effect. Jean developed a rare kidney illness. Her lawsuit is pending.

During the evacuation, Nurse Becky Mease's baby had projectile vomiting and severe diarrhea. The hospital in Ocean City, Maryland said it could be radiation poisoning and suggested she have her car checked for contamination. She did. It was, and so was her purse. Later, her child developed cataracts and other health problems.

Debbie Baker just found out she was pregnant. She lived in the vicinity of the dentist office with the fogged film. Debbie's son Bradley, was born with Down's Syndrome. The lawsuit on his behalf was settled out-of-court and was the largest made public, for over one million dollars. Debbie is one of the co-founders of the citizens' radiation monitoring networks around TMI.

Conclusion

Dr. Steve Wing of the University of North Carolina says, "The cancer findings, along with studies of animals, plants and chromosomal damage in Three Mile Island area residents, all point to much higher radiation levels than were previously reported. If you say that there was no high radiation, then you are left with higher cancer rates downwind of the plume that are otherwise unexplainable. Our findings support the allegation that the people who reported rashes, hair loss, vomiting and pet deaths after the accident were exposed to a high level radiation and not only suffering from emotional stress."

The accident at Three Mile Island was not a one day or one week disaster. TMI burped and vented their poisons upon us during the accident and through the years of clean-up. The symptoms were real. We did not imagine the metallic taste.

Health Studies: Another Source of Stress for Central Pennsylvanians

Central Pennsylvanians trying to cope with the accident at TMI and its aftermath agree with official government scientists on one thing: TMI-2 has generated a lot more stress than electricity. The worry and uncertainty surrounding the accident persists to this day. The effects of stress on health are widely documented. Worries about cancer, birth defects, the possibility of another accident, all stress the body's neurochemistry and can affect the functioning of the nervous system, hormone levels, and immune system responses. Virtually every study conducted agrees that there are increased levels of stress and that stress has deleterious effects on our health.

This is one aspect of the accident on which there is unanimity: Central Pennsylvanians don't believe the findings of "official"studies on the health effects resulting from Three Mile Island. Conversely, the officials demonstrate no interest in the solid evidence which has been collected by non-governmental sanctioned scientists and lay people.

The officially-sanctioned health studies following the accident (funded by state and federal government, MetEd/GPU and the nuclear industry) rely upon one radiation monitor which was, in fact, misrepresented by the President's Commission Report and the NRC's Special Inquiry Group. These reports fraudulently state that the HP-R-3236 monitor remained "on scale" during the accident but it actually went off scale high because of the radiation . Thus, there was no means to determine the size of the radioactive release. All these studies have as their basic assumption that not enough radiation escaped during the accident to harm anyone.

Put yourself in the shoes of a TMI neighbor and consider the following:

The recommended chromosome studies were not done on workers or residents because the official doses were declared too low and therefore, would not yield useful information. This is circular logic.

Three Mile Island's Health Effects: Two Decades of Deceit

What We Know

The truth is: people of Three Mile Island have suffered adverse health effects. Some of us have died. More will in the future as a result of the radioactive releases from the accident.

The March, 1982 issue of AJPH reported, "During the first two quarters of 1978, the neonatal mortality rate within a ten-mile radius of Three Mile Island was 8.6 and 7.6 per 1,000 live births, respectively. During the first quarter of 1979, following the startup of accident prone and leaking Unit 2, the rate jumped to 17.2 and increased to 19.3 in the quarter following the accident at TMI and returned to 7.8 and 9.3, respectively, in the last two quarters of 1979."

Increases in adverse health effects were also found by Penn State professor, Dr. Winston Richards. "Infant mortality for Dauphin County while average in 1978 becomes significantly above average in 1980. Death from leukemia while average in 1979 is very close to above average in 1980, and deaths from cancer for ages 45-64 while average for 1978 become decidedly significantly above average for 1980."

An unexpected finding has surfaced linking Sudden Infant Death Syndrome (SIDS) with elevated white blood counts, the eosinophils, and raising the question whether there is a causal relationship between increased SIDS and radiation exposure. A document from the Health Department entitled; "Resident infant deaths due to sudden infant death syndrome," shows huge increases of SIDS cases in Pennsylvania in 1974 after the startup of TMI Unit 1 and another large increase following the accident. In March, 1995, George Nobbe, a British pathologist, reported babies that died of SIDS had a three-fold increase of eosinophils in lung tissue. Coincidentally, people here had "persistently elevated eosinophils" and there were "very high eosinophil counts" in animals after the TMI accident as well. Furthermore, Dr. Joseph Leaser stated "eosinophilia could be a precursor to leukemia."

The Health Department's official cancer study was released in the fall of 1985 claiming they found no in-creases in incidences of cancer within a 20 mile radius of TMI caused by the accident. Shortly thereafter, the Sunday Patriot-News exposed the Health Department's obfuscation and their contrived results. The Pa. Department of Health had "included 28,610 people" who lived beyond the five mile radius of the plant and another 122,000 people who live farther than 10 miles from the plant were included in the population of those living within 10 miles, which substantially diluted any cancer rates.

A study by the University of North Carolina exposed how "official science" obfuscated what the people around TMI have always known: there was offsite radiation, there was radiation sickness, and now there are long lasting health effects.

The University of North Carolina study found AYthere were reports of erythema, hair loss, vomiting, and pet death near TMI at the time of the accident..." The study goes on to say, "Accident doses were positively associated with cancer incidence. Associations were largest for leukemia, intermediate for lung cancer, and smallest for all cancers combined.... Inhaled radionuclide contamination could differentially impact lung cancers, which show a clear dose-related increase." While "official" studies found problems, they concluded TMI wasn't the cause. The UNC study says of official studies AYpositive results have been interpreted as negative..."

Columbia's AJPH article of June 1991, actually shows there was more than a doubling of all observed new cancers after the accident at TMI - including lymphoma, leukemia, lung, colon and the hormonal category of breast, endometrium, ovary, prostate and testis. For leukemia and lung cancers in the 6-12 km distance, the number observed was almost four times greater and in the 0-6 km distance colon cancer was exactly four times greater. Their paper on cancer in proximity to the plant finds "a statistically significant relationship between incidence rates after the accident and residential proximity to the plant." So stress can be blamed for cancer, but radiation cannot.

Millersville University Study, James W. Fenwick, Assoc. Prof., biostatistician: Fenwick found in early 1998 that "Cancer rates in Lancaster County appear to be on the rise." Reporting statistically significant increases of prostate and urinary/bladder cancers in men; increases in kidney/renal, pelvis and ovarian cancers in women; and small increases in the rate of thyroid cancers in both men and women.

Lee Survey, Jane Lee, Unpublished Report: Mrs. Lee, surveyed 409 families in a small development within about five miles north, northwest of TMI, in one of the areas where the Pa. Department of Health refused to conduct an investigation. Since the accident Lee documented 23 cancer deaths, 45 living cancers, 53 benign tumors, 31 miscarriages, stillbirths and deformities, and 204 cases of respiratory problems. The "metallic taste" was reported by 98 people interviewed.

Aamodt Study, Marjorie M. Aamodt, Intervenor in the TMI proceedings: A "Voluntary Community Health Survey" was undertaken by a group of local residents led by Mrs. Aamodt. Two survey areas were canvassed where people reported "radiation symptoms" during the accident; a third area seven to eight miles away on a hill was chosen as a control. The results of the study compiled and analyzed by Mrs. Aamodt showed a 600% cancer death rate increase for all three areas, with the control group revealing health damage also. This data was verified by members of the TMI Public Health Fund and it was learned through a Freedom of Information Act Request that Dr. Glyn Caldwell of the Center for Disease Control wrote, "I do agree if all deaths the were confirmed by medical records, then this would be a statistically significant increase." The deaths have been confirmed.

The President's Commission Report is cited most often to refute radiation exposure as causing any health damage to the two million people living within the fifty mile radius of the plant; stating at most, only one cancer death would be expected. But this report, which misrepresented a critical radiation monitor as remaining on-scale during the entire accident from which questionable low doses were derived, is the root cause of the cover-up/controversy.

Admiral Rickover said that AYthe report, if published in its entirety, would have destroyed the civilian nuclear power industry, because the accident at Three Mile Island was infinitely more dangerous than was ever made public." He admitted persuading President Jimmy Carter"... to publish the report only in a highly 'diluted' form." (7-18-86 Notarized Affidavit by Jane Rickover.)

Security: Three Mile Island has a Long History of Problems

It is well known that the 1979 Three Mile Island accident cost utilities millions of dollars for safety upgrades at plants around the country. It is less well known that security problems at TMI have also triggered millions of dollars in security upgrades at American nuclear facilities.

In May 1975, two conscientious TMI security guards lost their jobs after raising security problems to the company management and the FBI. The pair held a press conference with Ralph Nader in Washington, DC, hoping Congress would handle this matter of national security. Nader called security a "sham." One of the TMI guards told the media that "Sabotage at Three Mile Island would be easy." Their revelations were proven accurate in a subsequent General Accounting Office report titled "Security At Nuclear Power Plants - At Best, Inadequate."

An intrusion in 1976 was somewhat comical. An intruder drove onto the site, climbed an un-alarmed fence and seemingly disappeared. About 35 minutes later he was heard singing from atop the reactor building. A search was conducted, but the individual eluded capture.

Suspicions of sabotage were raised during the 1979 accident investigation when investigators found peculiar wiring errors and closed valves. Particularly bothersome was a pair of "emergency feedwater valves," which could have prevented the accident if in the open position as required in the operating license. The President's Commission on TMI asked for a list of employees who might have long-standing grievances against the company and might have deliberately closed the valves. Then, in a letter to FBI Director William Webster, the President's Commission requested an FBI sabotage investigation and described the adequacy of the Nuclear Regulatory Commission's examination of the closed valves as "questionable."

Another embarrassing security incident happened shortly after the 1979 accident when a reporter was hired as a security guard. He used a false name and provided false information which even a simple background check would have revealed. He described entering the TMI control room unchallenged (only armed guards were permitted access). There was no lock on the door and a piece of knotted clothesline hung where the doorknob should have been. A college textbook uses this incident as an example of poor security. The book cites the reporter's headline, "Three Mile Island: It's a Paradise Island for the Saboteur." TMI's owners unsuccessfully sought a court injunction to block publication of the article on the grounds that it would compromise national security.

On February 7, 1993 TMI had its highest level of emergency since the 1979 accident when an intruder drove past TMI's guarded entrance gate, crashed through the protected area fence, crashed through the turbine building roll-up door, and hid in a darkened basement of the plant for nearly four hours before being apprehended by guards. Three weeks later, the bombing of the World Trade Center and these terrorists' threat to attack "nuclear targets" with "suicide soldiers," resulted in nuclear plants now being required to protect against truck bombs.

The World Trade Center terrorists trained 30 miles from TMI where they performed a night-time mock assault on an electrical substation. The FBI did not inform the NRC or TMI about the proximity of the training camp. It was a phone call from the chairman of TMIA's Security Committee, Scott Portzline, which first alerted the NRC to the training camp. Portzline=s warning to an NRC advisory committee about poor security at TMI ten months before the intrusion went unheeded. Portzline has also presented video testimony to the NRC showing how a saboteur can use publicly available documents, a boat, and an airplane to cause a catastrophic radiological release at nuclear plants.

The TMIA Security Committee urges the NRC to improve security at nuclear plants. In the face of threats from terrorists, greater control of industrial nuclear devices is also essential. The Security Committee is also concerned about terrorist attacks against high level waste shipments (spent fuel rods) which will soon crisscross the country.

Since the Restart: A Summary of NRC Citations and Fines for TMI-1

Procedures and hardware discarded in trash cans or "missing":

October25, 1985; November 8, 1986; May 5, 1987; October 22, 1988; September 11, 1990; June 7, 1992; January 4, 1993; and, November 4, 1994.

Radioactive waste mis-classified and returned to TMI:

July 3, July 17 to August 30, October 7 - 11 and October 8, 1991; April 6 - 10 and August 21, 1992; August 9 and December 1994.

Poor radiation posting and monitoring and worker contamination:

December 13, 1985 and January 18, 1986 and December 17, 22 and 30, 1985; February 28, March25, September 8 to October 3, October 3 to 31, 1986; February 24, March 7 and April 20 1987; June 17 - 19, July 11, July 22 and August 2, 1988; September 19, 1989; March 6 and April 12, 1990; February 3-7, October 19, December 5 and 12, 1992; October 4-8, 1993; June 6, 1994; and, March 8 and June 2, 1995; March 12 and April 24, 1997.

Fires, explosions, "boiling" and weak fire protection:

July 18, 1986; March 19, April 2 and July 27, 1987; March 6, 1988; June 12, July 15 and September 1 and 3,1991; January 14, July 27, and November 23, 1992; and, January 28, August 11 and September 30, 1993; and, September 29, 1994.

Drug abuse:

February 19, March 7 and 12 and June 15, 1987; July 19 and 30,1991; July 29 and August 29, 1992; and, August 18, 1997.

Steam generator problems and number of tubes removed from service:

March29, October 7, November 22 and 29, 1985; April 18, 1986 and December 18, 1986; March 23 and 31, May 1 and September 22, 1987; March 26 to April 30, June 20 and 21, August 7 and October 30, 1988; January 10 and March 6, 8, 19 and 22, 1990; November 4-8, 1991; and, September 28, 1992; October 12, 1995; March 12 and April 24, 1997.

Water chemistry problems:

May 1, 1987; March 19 and November 14, 1990; September 16 and December 3, 1994.

Control rod deficiencies:

October 23, 1985; March 16, 1988; January 15 and 26 and June 24, 1989; October 14, 1993; March 17, May 31, 1994 and June 9, 1994; September 9,1995; and, June 21, 1997.

Leaking fuel assemblies:

November 25, 1991 and December 5 and 12, 1991 and March 13 and 31, 1992; and September 28, 1995.

Inadequate design controls safety evaluations:

March 4 and October 10, 1997 ($50,000 fine).

Housekeeping flaws:

May 6, 1986 through October 31, 1986; March 22, July 9 and September 25, 1987; January 9 to February 6, June 13 and September 20, 1988; August 7 to September 21 and October 5, 1990; July 15, and December 26, 1991; January 14, February 6, February 2 to March 7, and April 3, 1992; December 19, 1997.

Emergency Diesel Generator Problems:

January 10-11, February 6 to March 6, March 2 and October 8, 1987; July 29 and November 9, 1988; November 4, 1989; May 12 and December 14, 1990; March23 and September 27, 1992; June 18, June 24- July 1, 1993; and, October 2, 1994.

Emergency Preparedness and Evacuation Planning Problems:

May 9 and June 2 and November 11, 1987 (Notice of Violations); August 11, 1993; May 19 and July 11, 1994; June 2, 1995; March 12, April 24 and June 27, 1997; October 10, 1997 ($55,000 fine)

Improperly downgrading safety equipment:

March 4 and October 10, 1997 ($50,000 fine).

Motor Operated Valve Program:

February 23, August 30 and September 9, 1994; August 17, 1995; September 13, 1996; and, February 26, 1996.

Safety Problems at Three Mile Island

TMI Flunks Recent Simulated Accident Test

(March 5, 1997) Three Mile Island operators failed an emergency test when they were not able to recognize that simulated accident conditions had reached levels requiring the declaration of an emergency. The company also failed to detect that conditions had deteriorated to the point where citizens outside the 10-mile emergency planning zone would be irradiated and that additional protective actions were necessary. This was sadly reminiscent of the 1979 accident when TMI operators and spokespersons misunderstood or denied the severity of the near meltdown.

Unprecedented Financial Pressures Threaten Safety at TMI

The greatest threat to safety since the 1979 accident is the extraordinary financial pressure now placed upon Pennsylvania's nuclear plants as a consequence of the new competitive electrical market (deregulation). In Pennsylvania, nuclear generated electricity is the most expensive of all electrical choices. To become financially competitive TMI and other nuclear plants are faced with stretching safety expenditures to unprecedented levels. (As many as 90 reactors could be forced to close before their scheduled retirement dates as a result of the competitive pressures expected from deregulation. Early plant retirements could create a $60 billion deficit for the long-term storage of high level nuclear waste and decommissioning costs.)

Shortly after the TMI accident, a vital admonition was made to state regulators from the NRC's independent investigation by the Rogovin Commission. Investigators warned that state Public Utility Commissions (PUC) should "eliminate incentives that might tempt a utility away from its commitment to safety. " But, Pennsylvania's legislators and the PUC have done exactly that. Three Mile Island Alert warns that an important lesson is being forgotten. The transition to a competitive market places a nearly impossible burden on nuclear plants for safe operation.

NRC Safety Findings at TMI

Personnel cutbacks have already caused problems at TMI. There has been a steady decline in the engineering program. The NRC gave its lowest grade for engineering practices to TMI in its most recent licensee performance review. One NRC official said that TMI management was "in denial" for not being able to identify the fundamental problem.

TMI recently began reclassifying safety-grade equipment to a lesser grade. This would allow for financial savings but could compromise safety. The NRC describes TMI⁼s efforts as ^Apoor^@and says they are concerned about the potential implications of bad management.

An NRC official stated that TMI's Emergency Diesel Generators are "as ugly as [he] had ever seen" and called them a fire hazard because of leaking oil. These generators are necessary to supply electricity to the plant for a safe shutdown when off-site power is lost. This function makes them an extremely important component for accident prevention. Diesel generators are not reliable and the frequency of breakdowns is high enough to cause concern amongst some nuclear "watchdogs." When a station blackout occurs (loss of off-site power), nuclear reactors shutdown by design. The diesel generators must immediately begin supplying electricity to maintain control of the cooling systems.

Two Steps to Another Accident

GPU President Fred Hafer stated that cost-cutting may effect electrical reliability because of decreased line maintenance and additional job cuts. The enormous western blackout of August 1996 was triggered by a transmission line which sagged onto a tree, faulting the circuit and thereby triggering the grid failure. The fundamental problem was a lack of line maintenance. Four nuclear reactors tripped as a result of the grid failure. Two had complications during the automatic shutdown which were successfully resolved. The NRC is uncertain about the future of grid reliability and has issued notices for nuclear plants to review station blackout procedures.

Combining the uncertainty of grid reliability (transmission and distribution of electricity) in the newly deregulated environment, with the diesel generator failure rate, the worry becomes one of coincidental failures. Deregulation could actually create the triggering mechanism for another nuclear accident by exacerbating conditions for a grid failure. (The Y2K problem can create the same conditions.)

Accident Scenario

The following hypothetical accident scenario needs only two simple failures to cause a meltdown or a catastrophic radiological release. (The 1979 accident involved at least five system failures or errors.) Assume that the grid fails causing a station blackout at TMI. If the diesel generators fail, a bank of batteries supply electricity to the control room and low-load electrical systems for about four hours. After that, if the grid or diesel generators are not restored, the reactor will become uncontrollable. The burden of deregulation makes this scenario more likely than ever. The NRC has stated this same concern in a briefing on grid reliability.

Impact of Deregulation

The negative effects of deregulation on nuclear plant safety should not be underestimated. Financial pressures permeate every aspect of nuclear safety. Overworked and disgruntled employees will become a serious problem facing utilities as a result of deregulation. Because many employees are being laid off, fewer are willing to raise safety concerns for fear of losing their jobs. Future employment in the nuclear industry is bleak and morale is going down. Safety inspections of certain systems are becoming less frequent. Cost-cutting jeopardizes safe operation. The stage is being set for another accident in the United States. Three Mile Island Alert projects that another accident at a US plant will occur within the next decade . Some of us believe within the next three years.

Fire Barrier used at TMI is Ineffective

The NRC had to notify TMI once again to replace a faulty fire barrier material. Thermolag actually burns at the same rate as ordinary plywood. What makes this problem so perturbing to nuclear watchdogs is that the NRC knowingly sat on this problem from 1982 until 1993. There has never been a hurry to fix unresolved problems at nuclear plants. When the NRC Chairman finally admitted "We screwed up," a TMI spokesperson said that they had no plans to replace the faulty material at TMI. Now the NRC has given TMI yet another year and a half to comply. More than 16 years have passed since initial concerns on this safety defect were raised without a change at "'MI.

A January 1999 General Accounting Office audit of the NRC stated "Since 1979, [six) various reviews have concluded that NRC's organizational structure, inadequate management control, and inability to oversee itself have impeded its effectiveness. The NRC's oversight has been inadequate and slow."

Slow Control Rods at TMI

Control rods must be able to drop into the reactor core within 1.66 seconds to halt the nuclear chain reaction. While TMI boasted that it set a duration record between refueling outages, TMI has experienced problems with a build-up of a boron crud around the drive mechanism. This slowed control rods by as much as 173 percent over the time limit. The crud is a result of new longer fuel cycles which cuts fuel expenses but creates other problems. TMI asked the NRC for an exemption to allow the slower drop times. Later, TMI decided to add more chemicals to counteract the boron in the reactor coolant and to manipulate the control rods frequently to prevent excessive crud. Managing the problem in this manner causes faster wear of the drive mechanism and could lead to a failure if not watched closely.

Pressure to Stay On-Line

Plants are in a big hurry to get back on-line after a shutdown because of financial pressures. At "TMI, a reactor operator used an unauthorized method to fill the reactor with coolant which resulted in an uncontrolled radioactive spill through the control rod mechanism. Plants are reluctant to shutdown for repairs. More and more plants are doing testing and repairs while online without assessing the dangers that it presents.

More NRC Safety Findings at TMI

Due to a wiring error and the failure to conduct a post-maintenance test, the power-operated relief valve (PORV) was left inoperable from a refueling outage in October 1995 until the most recent outage which began in September 1997. The PORV is same type of valve which stuck open causing the 1979 loss of coolant accident and is still not listed as a safety component by the NRC .

Following work in the plant's fuel transfer canal, which is used to move fuel between the spent fuel pool and the reactor, a worker was contaminated. This was caused by a failure to conduct detailed radiation surveys and to take actions to control the spread of radioactive particles. During steam generator tube inspections, workers left a high-radiation area entrance unlocked.

Generic Problems

A problem facing the entire industry is the "Year 2000 Problem." GPU says that they are on schedule to fix the problem at "TMI. GPU is behind schedule at their sister plant in Oyster Creek, New Jersey. A single line of errant computer code has the potential of causing big problems at nuclear plants. If the electrical grid becomes degraded, emergency diesel generators must supply power to the plant. These emergency generators have experienced frequent failures.

Aging reactors are having problems with reactor steel embrittlement and leaking steam generator tubes. TMI has had trouble with leaking steam generator tubes and leaking condensor tubes.

Defueling TMI-2: A Litany of Problems

Three Mile Island Unit-2 was built at a cost to rate payers of $700 million and had been on-line for just 90 days, or 1/120 of its expected operating life, when the March 1979 accident occurred. One billion dollars was spent to defuel the facility. Three months of nuclear power production at TMI-2 has cost close to $2 billion dollars in construction and cleanup bills; or the equivalent of over $10.6 million for every day TMI-2 produced electricity. The above mentioned costs do not include nuclear decontamination and decommissioning or restoring the site to "Greenfield" status.

At the time of the accident, TMI's owners had no moneys put aside for decommissioning. General Public Utilities' (GPU) customers contributed three times as much for the defueling effort than the corporation that caused the disaster, $246 to $82 million. In January 1993 the Pa. Public Utility Commission (PUC) refused GPU's request to hand their customers the TMI-2 decommissioning bill estimated to be at least $200 million. However, several months later, the PUC reversed itself and gave GPU permission to pass the cost of decontamination and decommissioning TMI-2 onto the rate payer. This decision to financially assess GPU rate payers far the accident was upheld by the Pennsylvania Supreme Court. In 1995, GPU hired a consultant to conduct a site-specific decommissioning study for TMI-2. The "retirement costs" for TMI-2 was estimated to be $399 million for radiological decommissioning and $34 million for non-radiological removal.

Although the plant is scheduled to be decontaminated and decommissioned in 2009, if plant owners requests a five year extension on their license, these activities will not begin until 2014; fully 35 years after the accident.

The cleanup of TMI-2 has been fraught with problems:

In July 1980, Met Ed (GPU) vented more than 100,000 curies of radioactive Krypton-85, and other radioactive gasses directly into the atmosphere. TMI-2 was designed to release approximately 770 curies of Krypton-85 a year. Four months later in November 1980, the United States Court of Appeals for the District of Columbia ruled that the krypton venting was illegal.

On August 12, 1982, cleanup worker William Pennsyl was fired for insisting he be allowed to wear a respirator while undressing men who entered highly radioactive areas. Pennsyl filed a complaint with the U.S. Department of Labor and, on April 11, 1984, settled Out of court two days before an administrative law judge was scheduled to hear his case.

On March 22, 1983, TMI-2 senior-safety, start-up engineer Richard Parks publicly charged GPU and Bechtel Corporation with deliberately circumventing safety procedures, and harassing him and other workers for reporting safety violations. Parks filed a complaint with the U.S. Department of Labor. On August 12, 1985, GPU and Bechtel were fined $64,000 for the incident by the Nuclear Regulatory Commission (NRC).

From July 24-27, 1984, during the reactor head lift, which was delayed due to brake failure on the polar crane, GPU vented radioactive gasses into the environment. The venting occurred despite pledges by GPU and the NRC that no radioactive releases would take place during the head lift operation. GPU was fined $40,000 for the violation by the NRC.

In May 1987, a non-licensed plant employee was suspended after he was found sleeping in the radioactive waste control room. Two months later, ten employees working at TMI-1 and TMI-2 tested positive for drugs; eight individuals were suspended for 30 days without pay and one resigned. Thirty three people were arrested in all. Since March 1986, 16 employees tested positive for drugs at TMI.

On December 1, 1987, GPU announced the firing of a shift supervisor for sleeping on the job. Although the employee had a record of sleeping on the job dating back to the early 1980s, GPU did not issue a warning until October 1986. Edwin Stier, former director of the New Jersey Division of Criminal Justice, reported that 21 witnesses saw the shift supervisor asleep on the job.

In December 1990, GPU began evaporating 2.3 million gallons of accident-generated radioactive water (AGW) into the atmosphere. In April-May 1991, the evaporator was shut down for most of this period so GPU could "rewrite the main operating procedure." A Notice of violation was issued by the NRC. In January 1993, GPU "discovered" they failed to take periodic samples of approximately 221,000 gallons of AGW in the borated water storage tank. Evaporation was completed in August 1993, six months behind schedule.

In August 1993, Dr. Michio Kaku, Professor of Nuclear Physics, City University of New York, evaluated studies conducted or commissioned by GPU and the NRC on the amount of fuel left in TMI-2. Dr. Kaku concluded, "It appears that every few months, since 1990, a new estimate is made of core debris, often with little relationship to the previous estimate... estimates range from 608.8 kg to 1,322 kg.. This is rather unsettling... The still unanswered questions are therefore: precisely how much uranium is left in the core, and how much uranium can collect in the bottom of the reactor to initiate re-criticality?"

Plant Longevity: Nuclear Generating Stations Fall Short of Expectations

On January 15,1998,Commonwealth Edison announced it was permanently shutting down Zion-1 and Zion-2, 1040 MWe Westinghouse PWRs. Zion-1 began commercial operation in December 1973, followed by Zion-2 in September 1974. Com Ed reported this decision will cost shareholders $515 million or $2.38 per share. With the premature closure of these Zion, Illinois units, every American commercial nuclear reactor type and supplier has experienced early retirement, well before their projected 40 year operating life was achieved.

At a hearing on a PP&L rate case, the nuclear industry's leading decommissioning consultant, Thomas LaGuardia (principal of a consulting company called TLG), was asked by TMIA Chairman Eric Epstein "How many commercial nuclear power plants in this country have completed their full operating lives?"

Mr. LaGuardia replied: "None, essentially." (PP&L Base Rate Case, Page 1023, Lines 20-22.)

A sense of fiduciary accountability and fair play dictate that utilities plan for decommissioning based on the assumption that their nuclear units will be prematurely shut down. The chief indicators the nuclear industry relies on to measure plant longevity are spurious and imprecise. Obviously, as the list below documents, there is a chronic shortfall between "targeted" funding levels and actual costs for nuclear decommissioning. The burden of proof rests squarely on the shoulders of electric utilities to demonstrate that a 40 year operating life, upon which they predicate their financial planning, is realistic. The nuclear industry has exacerbated this problem by resolutely refusing to put aside adequate funds for nuclear decontamination and decommissioning.

The following reactors have been shut down prematurely:

TMI-2, a 792 MWe reactor operated for 1/120 of it planned operating life (December 1978 to March 1979), when it experienced a partial core meltdown. Twenty years later, the plant has been defueled at a cost of $1 billion, but has yet to be decontaminated and decommissioned. GPU also owns the Saxton Nuclear Experimental Facility, a 7 MWe reactor placed in "temporary storage" in 1972 and dismantled at a cost of $12 million, 200% above the original capital costs.

Fermi-1, a 57 MWe reactor, operated for 75 months before it was shut down in 1975 and placed in "temporary storage" due to an accident.

Indian Point-1, 257 MWe reactor functioned for 30% of its planned operating life (January 1963 to October 1974), was shut down to comply with Atomic Energy Commission regulations; the plant lacked an emergency core cooling system.

Rancho Seco, a 873 MWe generating station completed in 1975 and operated for 127 months before it was shut down in 1992 by a voter referendum.

Humboldt Bay, a 63 MWe unit, operated for 155 months before being shut down in 1976. The cost of refurbishing the plant to withstand a major earthquake was more than the original licensing and construction costs. This facility remains in "temporary storage" with no funds accumulated to decommission the plant.

Dresden-1, a 200 MWe reactor operated for 45% of shelf life (July 1960 to October 1978), and was forced to Close prematurely due to corrosive radioactive piping. This unit was "partially" decommissioned with chemicals in the early 1980s, but remains in "temporary storage" until Dresden-2 and -3 are "retired." In January 1994, cold weather caused cracks in the water service system causing 55,000 gallons of radioactive water to spill.

Shoreham, 809 MWe, operated for two full-power days (which is .000136986% of the estimated life of the Susquehanna Steam Electric Station) and closed before it could begin commercial operation in May 1989. The fuel from this plant was shipped to the Limerick plant near Reading, Pa.

Fort Saint Vrain, a 330 MWe operated for 27.5% of its expected life (1/79 to 8/89).

Jan, 1080 MWe unit, operated for 40% of its operating life (5/76 to 11/92), and was forced out of service due to chronic steam generating tube problems.

San Onfore-1, a 436 MWe only operated for 35% of it projected operating life (January 1968 to November 1992).

Big Rock Point, a 67 MWe General Electric BWR began commercial operation in November 1965 but was forced to close prematurely in 1996.

On December 4, 1996, Haddam Neck, a 582 MWe Pressurized Water Reactor operated by Connecticut Yankee Atomic Power Company, closed prematurely in the hope of saving rate payers $100 million ("Nuclear Monitor," p.4, December 1996.) The plant came on-line in January 1968 and operated for 72.5% of its predicted life.

On May 27, 1997, Maine Yankee was shut down and became the first Combustion Engineering reactor to be prematurely retired. The plant, an 860 MWe Pressurized Water Reactor, opened in 12/72 and was scheduled to operate through 2008.

The Connecticut Department of Public Utility Control removed Millstone-1 from the rate base on December 31, 1997. Millstone-1, a 660 MWe General Electric Boiling Water Reactor operated by Northeast Utilities, began operation in March 1971 before being prematurely retired. More importantly, the decision prevents Northeast Utilities from charging rate payers for costs associated with the shutdown.

Electric Deregulation

"As the electric industry becomes subject to greater competitive pressure and as the bargaining power of some large customers grows even stronger; the Office of Consumer Advocate submits that the Commission must be vigilant in ensuring that the costs of these developments not simply be foisted upon those customers who lack any semblance of market power:"

Pa. Public Utility Commission v. Pennsylvania Power & Light, October 25, 1995.

Left to its own devices, the electric industry will seek the least cost fuel option with no incentive to contain rates or minimize environmental pollution. Electrical demand has been reduced by two consecutive recessions in the 1980s, energy efficiency, conservation, and demand side management (DSM). Technologies have vastly changed since the 1970s when economics of scale encouraged centralized generating stations. Smaller more efficient facilities have supplanted the economic boondoggles of the 1970s. Deregulation, under the guise of competition, will inevitably roll back gains in efficiency and environmental programs.

Job security has become the first casualty in the industry's desperate attempt to reduce costs. Pennsylvania utilities have substantially reduced labor costs through attrition, "downsizing," and voluntary retirement pro-grams. For example, at a PUC proceeding in May, 1997, a PP&L spokesman said, "During calendar 1992 through the calendar year 1996, separations from employment at PP&L totaled 1,615 people."

The most economical plants are the oldest and dirtiest and deregulation would militate against DSM and energy efficiency since power suppliers would be enticed to sell bulk electricity on the retail market. There are substantial overt and hidden costs associated with a continued dependency on "hard energy." Deregulation will facilitate a "race to the bottom" and hasten a return to uneven state compliance laws and procedures.

Electricity rates do not take into account all the costs of the harmful effects of electricity production. In meeting environmental requirement, utilities incur costs - for pollution control equipment, for example - that are considered internalized environmental costs because they are included in electricity rates. However, other costs - those for residual pollution emission, which are not controlled - are not reflected in electricity rates. Government Accounting Office, "Electricity Supply: Consideration of Environmental Costs in Selecting Fuel Sources," May 19, 1995

Pennsylvania's electrical production is dominated by coal and nuclear fuel: Coal accounts 56.43% of the state net generation, while 41.02% is supplied by nuclear sources.

The remainder of the energy mix is as follows: oil = 0.56%; gas = 0.20%; and hydroelectric = 1.80% ("Electric Utility Operational Report," January 1997, p.1.). Electric utilities, the primary consumers of domestic coal, burned 78% of the 998 millions of coal produced in the United States in 1992. With the transfer of emission "allowances" and possible weakening of the Clean Air Act, increased coal production may come at the price of accelerated environmental degradation.

The Pennsylvania electric industry's solvency is ensured through massive governmental subsidies and relies on an energy mix which is not now, or for the foresee able future, competitive in a free and open market. According to the Congressional Research Service, nuclear power received 60% of all federal research and development money from 1948-1994 or $97 billion since 1950.

These industry actors, for the most part, find themselves nicely insulated from the cost of waste management. The Price-Anderson Act, for example limits industry liability, and nuclear waste policy act allows utilities to pass waste management costs through to rate payers. Thus nuclear waste management costs, like nuclear wastes, are a residue of the 195 Os nuclear promotion policy. Moreover, a portion of nuclear wastes and their management costs are the result of improperly under-pricing nuclear electricity and creating an over-investment in nuclear plants and equipment. (Luther J. Carter, "Jurimetrics Journal," Fall, 1988.29 JURIM J 97.)

This translates into expensive nuclear generated electricity, of which Pennsylvania is dependent. Pennsylvania utilities have disproportionately higher rates based on their percentage of nuclear assets. The list below shows the percentage of each company's nuclear generating capacity and the cost per kilowatt hour of electricity:

Philadelphia Electric Company (PECO) 58% 11.78 cents per kWh

Dusquesne Light Company 30% 12.46 cents per kWh

General Public Utilities (GPU) 23% 9.12 to 8.86 cents per kWh

Pennsylvania Power & Light (PP& L) 31% 8.6 cents per kWh

West Penn Power (West Penn) 0% 6.85 cents per kWh

Stranded Costs and Nuclear Decommissioning

The Pennsylvania nuclear industry has pursued a financial investment in nuclear energy which was knowingly fraught with huge uncertainties. It is grossly unfair and inequitable to request the rate payers to provide a financial safety net for the utilities' risky nuclear investment strategy. TMIA argues that rate payer equity and corporate accountability necessitates that a substantial portion of "stranded costs," relating to nuclear decommissioning and nuclear waste disposal, should be borne by the entities that are traditionally held responsible for imprudent and unreasonable management decisions - the electric industry shareholder.

Current decommissioning "guesstimates" rely on three factors:

1) The development of nonexistent technologies;

2) Anticipated projected cost of radioactive disposal; and,

3) The assumption that costs for decommissioning small and short lived reactors can be accurately extrapolated to apply to large commercial reactors operating for forty years.

At the Susquehanna Steam Electric Station (SESS), projected costs for decommissioning have increased by 553% since 1981. In 1981, PP&L engineer Alvin Weinstein predicted that PP&L's share to decommission SESS would fall between $135 and $191 million. By 1985, the cost estimate had climbed to $285 million, and by 1991 the cost in 1988 dollars for the "radioactive portion" of decommissioning was $350 million. The company then contracted out for a site-specific study which projected that the cost of immediate decommissioning would be $725 million in 1993 dollars. The 1994 cost estimate remained steady at $724 million, but the market value of securities held and accrued in income in the trust funds declined, and thus the estimate reflected another increase in decommissioning costs for rate payers.

The cost estimates for non-radiological decommissioning (an imprecise term) are not mandated by the NRC although the agency stipulates that all nuclear power plants be returned to Greenfield status, that is, the original environmental status of the facilities prior to construction of the nuclear power plant. The fact that Greenfield has not been achieved by any large commercial nuclear plant and utilities are not required to save for this phase, places additional strain on a company's ability to finance radiological and non-radiological decommissioning.

Given the uncertainty surrounding decommissioning, radioactive waste costs, unavailability of radioactive waste disposal facilities, and increased safety concerns surrounding nuclear plant operation, the prudency of the utility's decision to dedicate large amounts of capital to the nuclear venture are called into question. Reasonable and prudent utility decision-making demand more than a simple acknowledgment of an industry-wide change in the form of a rate hike request. As stated by the Court in Duquesne Light Co. V. Barasch, 488 U.S. 299 (1989), the proper scope of analysis for the Commission is whether the decisions at the time, were "reasonable and prudent."

On the issue of decommissioning, the state Public Utility Commission stated that "Decommissioning cost estimates are inherently uncertain and speculative" and that "[t]o date, there has been no actual experience decommissioning a large, commercial nuclear plant and cost estimates have been traditionally low." In addition, the Commission held that "The current shortage (indeed nonexistence) of the site for the disposal of large quantities of radioactive waste makes detailed estimates of shipping distance and cost virtually impossible." Id. at 540-41.

The nuclear industry is not entitled to a full and complete rebate on "stranded investments." These companies must assume responsibility for their business decisions. The industry aggressively sought to license, construct and operate a nuclear facility despite the fact that the riddle of how to resolve the "back-end" of nuclear power production (nuclear waste disposal and decommissioning) had not been solved. To allow Pennsylvania nuclear utilities to recover 100% of decommissioning funding from the rate payer would be a defacto endorsement of corporate socialism. That is, shareholders profit from their investment decisions but are accorded rate relief when their imprudent and speculative decisions become uneconomical. Additionally, complete rate recovery on speculative investments such as "stranded costs," penalizes electric utilities such as West Penn Power which responsibly pursued a non-nuclear electric portfolio.

Unless a more equitable funding formula for decommissioning is established, rate payers who are not yet born will be burdened for payment for the cleanup of a plant from which they derived no benefit. Society as a whole, and the industry in specific, must assume responsibility for the decisions it makes. Creating and perpetuating intergenerational problems is not constructive, prudent, or equitable.

Nuclear Decommissioning and Long-Term Waste Storage

To date, no large, commercial nuclear power plant has been decommissioned. Costs are unknown and typically underestimated. The seminal study in this area was conducted by Battelle Pacific Northwest Laboratories which examined decommissioning costs between 1979 and 1982. Battelle's studies have long provided the criteria for utility estimates, despite the fact they were based on a 22.5 megawatt nuclear power plant, Elk River, which operated for approximately four years. This reactor was 1/40 of TMI's size. These studies were not revised to take into consideration a large boiling water reactor like Peach Bottom or a pressurized water reactor like Three Mile Island until 1993. This means cost projections and monies put aside for future decontamination and decommissioning are grossly inadequate.

At the time of the accident, TMI's owners had put no monies aside for decommissioning. During the next fifteen years customers of General Public Utility (GPU) contributed three times as much for the defueling effort than the corporation that caused the disaster ($246 to $82 million). In January 1993 the Pennsylvania Public Utility Commission (PUC) refused GPU's request to hand their customers the TMI-2 decommissioning bill estimated to be at least $200 million. However, several months later, the PUC reversed itself and gave GPU permission to pass the cost of decontamination and decommissioning TMI-2 onto the ratepayer.

Although the Nuclear Regulatory Commission (NRC) has stated they have "considerable experience [decommissioning] with reactors that have not had a significant accident before the end of their useful lives," that experience is limited to small prototype reactors. Decommissioning and decontamination technology of "retired" reactors is in its infancy and not much meaningful research is being conducted. The entire industry is deferring instead of developing. Due to the lack of technology and funding, damaged and prematurely "retired" plants such as Humboldt Bay, Dresden-1, Indian Point-1, Fermi-1, Peach Bottom-1, Rancho Seco, Trojan, Shoreham, Yankee Rowe, and TMI-2 serve as radioactive waste sites across America.

Several trends are apparent by examining these reactors: in each case "temporary" storage was prompted by financial considerations; prematurely shut down reactors place a strain on the licensee's cash flow; there is a prevailing reluctance to conduct or sponsor decontamination and decommissioning research; and, the NRC accepts the "temporary" storage of useless reactors as legitimate.

Concurrently, each nuclear plant stores highly radioactive waste in the form of spent fuel on-site. Each operating reactor produces 20 to 30 tons of this waste annually and there is nowhere for this radioactive garbage to go. For example, at TMI-1 there is more than 265 metric tons of spent fuel stored on site and at Peach Bottom-2 and -3 there is a combined total of more than 720 metric tons stored near the Susquehanna River. The technology to safely manage and isolate spent fuel, some of which will remain radioactive for several thousand years, does not exist.

Aggravating this situation is the critical shortage of waste disposal space for "low level" (which does not mean low-risk) radioactive waste. "Low-level" radioactive waste is anything that is not high-level, about 80% of the volume and 92% of the radioactivity which emanates from nuclear power plants: irradiated components and piping; control rods; poison curtains; resins, sludge, filters and evaporator bottoms; even the remains of entire nuclear power plants when they are decommissioned.

Three Mile Island Unit-1 has received permission to store "low-level" waste on-site until at least 2000, despite the fact the facility was not designed, licensed nor constructed to house radioactive waste. How much additional waste is this? In 1992, TMI-1 shipped 7,500 cubic feet, while Unit-2 sent 16,000 cubic feet for burial to Barnwell, South Carolina.

Every "low-level" nuclear waste dump in America has failed to contain radioactive elements, often with disastrous results, as was the case in Maxey Flatts, West Valley, and Beatty. The obvious solution to this dilemma is to reduce the radioactivity and volume of nuclear waste. This necessarily means the gradual phasing out of nuclear power production. Until then, radioactive waste must be stored above ground in monitored and retrievable isolation facilities. It is unfair and immoral to bequeath this mess to future generations.

PECO Buys TMI-1: Let the Public Beware of the Buyer

On July 17, 1998, AmerGen, a corporate venture comprised of PECO Energy and British Energy, made an offer to buy Three Mile Island Unit-1 for $100 million (or $500 million less than its book value). The proposed sale would pay the current owners, General Public Utilities (GPU), $23 million for the nuclear plant and $77 million for nuclear fuel over a five year period. Unfortunately, this marriage is a Faustian Pact that would yield PECO and GPU short-term economic relief while exposing area residents to increased health and safety risks:

PECO Energy has the highest electric rates in the state for all classes of customers. (PUC, Electric Utility Operational Report, January 30, 1997.) PECO also has the second highest average residential natural gas rates in the Commonwealth. (PUC, Natural Gas Utility Update, August 19, 1998.) In addition, "Philadelphia Electric was significantly worse than average" in the handling of consumer complaints and "worst in the industry," in collections. Bureau of Public Liaison, PUC, Fall 1995.)

On June 12, 1998 the NRC fined PECO $55,000 for "two program deficiencies that led to the impaired performance of a Unit-3 emergency cooling pump..." (NRC Inspection Report Numbers 50-277/98-03 & 50-278/ 98-06.)

On May 27, 1998, the United States Department of Justice sued PECO for more than $67 million in damages because the company allegedly reneged on an arrangement to buy 30% of the River Bend nuclear power plant which is owned by the Cajun Electric Power Cooperative. (Reuters, Wednesday May 27, 1998.)

In March 1998, "The Company reported a net loss of $1.5 billion or $6.80 per share. Included in these results was an extraordinary charge of $3.1 billion ($1.8 billion net of taxes), or $8.24 per share, in the fourth quarter to reflect the effects of the December 1997 PUC order (as revised in January 1998) in the Company's restructuring proceeding." (Report to Shareholders, C. A. McNeil, Jr., Chairman, President and CEO, PECO Energy.)

PECO was ordered by the Nuclear Regulatory Commission (NRC) to shut down Peach Bottom-2 and -3 on March31, 1987, due to operator misconduct, i.e., sleeping, spitball battles, and purveying "adult" magazines. This was the first and only occasion that the NRC ordered a nuclear power plant shut down. Zack Pate, President of the Institute for Nuclear Power Operations (an industry think-tank), declared that Peach Bottom "was an embarrassment to the industry and to the nation ... The grossly unprofessional behavior by a wide range of shift personnel... reflects a major breakdown in the management of a nuclear facility."

PECO's partners at Peach Bottom, Public Service Electric & Gas Company, Atlantic City Electric Company and Delmarva Power & Light Company, sued PECO for breaching the Owners Agreement. Philadelphia Electric agreed to pay $130,985,000 to resolve the litigation.

In 1997, PECO employees falsified reactor coolant chemistry reports to the NRC.

PECO has demonstrated that it does not possess the requisite character and integrity to operate its own plants: Boiling Water Reactors. Never mind that Philadelphia electric has never operated a Pressurized Water Reactor TMI-1 )

Historic and fiscal trends are valid and instructive barometers of future performance. PECO Energy has demonstrated an operating arrogance unmatched by any Pennsylvania utility. Rather than acquiring aging nuclear reactors, PECO should put its own financial house in order, marshal its resources toward improved performance and make a concerted effort to reduce their electric and gas rates.

TMIA: About Three Mile Island Alert

Three Mile Island Alert (TMIA) is a non-profit citizens' organization formed in 1977. Over the years, TMIA has been in the forefront, actively involved with many Three Mile Island-related issues including:

active intervener before the Nuclear Regulatory Commission (NRC) in hearings involving safety, technical and managerial issues
monitoring and tracking chronic safety, technical and managerial problems at TMI
tracking adverse health effects as a result of the TMI-2 accident and the normal operation of Unit-1(since 1974)
participating in two radiation monitoring networks
evaluating security problems at the Island
providing information, research, and educational materials to the general public, the news media, scholars, and elected officials.

TMIA's achievements include:

a landslide vote in a referendum against restarting Unit I after the accident

relief for ratepayers from accident-related expenses

creation of the TMI Health Fund

establishment of monitoring systems around the plant

successfully lobbying for vehicle barriers at nuclear plants

successfully lobbying for potassium iodide stockpiling near nuclear facilities

staging of numerous rallies, meetings, conferences, fund raising events and the continuous publication

of a regular newsletter

a coordinating role for the many safe-energy groups and individuals who have done battle with the nuclear power establishment.

TMIA also serves as regional clearinghouse on a broad spectrum of issues relating to nuclear power production including problems at Peach Bottom-2 and -3, Susquehanna-1 and -2, and the proposed siting, licensing, and construction of a low level radioactive waste dump in Pennsylvania.

TMIA has enjoyed wide public and political support in its watchdog role. In the spring of 1987, TMIA was recognized by the Pennsylvania House of Representatives for 10 years of community service. The House, along with the City of Harrisburg, applauded TMIA's efforts on behalf of the community at TMIA's 20th anniversary.

TMIA's policy is formulated by a seven member planning council which meets quarterly. TMIA meets regularly with the NRC and Pennsylvania Department of Environmental Resources to discuss issues and problems relating to TMI-1 and -2. The organization has two part-time volunteers who staff the office. In addition, several individuals write, edit, and mail TMIA's newsletter which is issued five to six times a year. All of TMIA's funding comes from membership dues, private contributions and fund raising events.

TMIA's office is open Monday through Friday from 10:00 am to 6:00 pm. Weekend visits are available by appointment. The public and all interested parties are encouraged to stop by or contact the group by phone or mail and to visit our web site at http://www.tmia.com.

Planning Council

Chairman - Eric Joseph Epstein

Eric is a Ph. D. candidate at Penn State. He is the co-author of Dictionary of the Holocaust: Biography, Geography, and Terminology (Greenwood & Westport Press, 1997) and is the Coordinator of the EFMR Monitoring Group at Three Mile Island. He is a visiting professor of humanities at Penn State Harrisburg and a GED testing coordinator for the Tri-County Opportunities Industrial Center (OIC).

Vice Chairman - Bill Cologie

Bill is a graduate of Penn State - Harrisburg and serves as president of a telecommunications trade association. He owns a small business in Harrisburg and served for many years as editor of "The Alert," TMIA's newsletter. Bill also serves on the Boards of the Dauphin County Library, the Pennsylvania Information Highway Consortium, the Pa. Coalition for Adult Literacy, and The Tuesday Club.

Secretary - Kay Pickering

Kay, who has made a career of volunteerism, is one of the founders and organizers of TMIA. She has been TMIA's office staff person for its entire history. She also does volunteer work for the Harrisburg Fair Housing Council, the Harrisburg Center for Peace and Justice, and is a Board Member of the Neighborhood Dispute Resolution Center. She has a BS in nursing from Earlham College in Richmond, Indiana.

Treasurer - Betsey Robinson

Betsey, officially Mariam Elizabeth Robinson, is a third grade teacher in a public school and a concerned mother. She has also been with TMIA from its very beginning serving in numerous volunteer capacities over the last two decades.

Mary Osborn

Mary is a paralegal with an Associate's Degree. She has been a TMIA member since May, 1979, alerted to the dangers by two family members, both of whom were construction workers at TMI. She has made dozens of presentations about the health effects of the TMI accident in Europe, Asia, and throughout America. Her exhibit of mutated flora and fauna from the TMI area has been seen by thousands and was recreated by Akira Kurosawa in his film Dreams. She has been recognized as one of Central Pennsylvania's "Top 101 Doers" by Apprise Magazine.

Scott Portzline

Scott is TMIA's security expert. He has testified before the Pa. House of Representatives, the U.S. Senate, the Nuclear Regulatory Commission and the "Advisory Committee on Reactor Safeguards" regarding the potential for sabotage at nuclear plants. He is a piano tuner by trade who has discussed nuclear security issues on both local and national broadcasts. He also researches lost and stolen nuclear materials in the United States.