OPEN LETTER TO THE CHAIRMAN OF THE NRC

and to the Chairman, Atomic Safety Licensing Board, Washington, DC 20555

Docket 50-289SP/TMI Unit 1 to go on record as a Limited Appearance Statement in the Hearings on the Restart and Licensing of Unit 1, Three Mile Island (TMI-1)

15 November 1980

The prolonged delay in restarting Unit 1 of Three Mile Island nuclear plant (TMI-1), which was neither damaged nor involved in the March 1979 incident, is costing lives, for its undelivered power is being replaced by electricity from less safe sources.

75% of the power now being bought by Metropolitan Edison to replace TMI is coal-fired [1]; prorating the number of premature deaths due to coal-fired plants alone, and by air pollution alone, I find (using mainly the detailed data collected by Brookhaven National Laboratory and published in the report by the Congressional Office of Technology Assessment) the median number of such deaths due to the idle TMI-1 capacity of 792 MW to be more than two per week [2]. That means that more than 173 premature deaths have by now occurred; and with 50% probability, that number has been exceeded.

It is true that these fatalities caused by the failure to restart TMI-1 are not individually traceable, and that most of them are elderly people whose lives are shortened by comparatively small periods. They die nevertheless; they die unnecessarily; and they die by the slowness of a process that was intended to protect the health and safety of the population.

Antinuclear propagandists such as the so-called Union of Concerned Scientists are free to frighten people with the risks of nuclear power while concealing from them that it presents a risk reduction (albeit not to zero) from the hitherto used methods of generating electricity. The NRC, I submit, has no such freedom, for its mandate makes it responsible for assuring public health and safety in regulating the civilian nuclear industry.

I therefore urge the NRC to re-licence TMI-1 for immediate start-up, not only because its continued shut-down is unjustified and discriminatory, but because it costs lives for which the NRC is, by its mandate, legally accountable.

[1] Best estimate by personally contacted spokesman of General Public Utilities. [2] The Direct Use of Coal, OTA Report, Washington, D.C., 1979; median number of deaths based on BNL data, p.218, interpolated for 1980; fraction of coal used for electric power generation 0.776 (DOE/EIA 1979), pro-rated for TMI-1 75% of 792 MW vs. 228,900 MW total US coal-fired capacity (DoE 1979). Not considered: excess casualties in the mining and transportation of coal vs. uranium for the same delivered electric power, excess casualties in the fuel cycle of oil-fired power plants, nor local effects (Pennsylvania is far above average in coal-fired air pollution and correlated mortality). All of these would cause the estimate to increase above the 2 deaths/week given here.

[Note to AtE readers. Readers are encouraged to join Friends & Family of TMI, Box 82, Highspire, PA 17034; and to write to the NRC and Congress about this and other nuclear plants shut down or not allowed to work at full capacity. However, they should be careful not to appear as opponents of coal and not to let the anti-growth crowd play up one energy industry against another (as they have succeeded in doing by duping the bosses of the United Mine Workers' Union into a strident antinuclear stand). Nuclear is healthier than coal; but coal is far healthier than lack of energy.]