CCAM NEWS 2004

Connecticut Coalition Against the Millstone Nuclear Power Reactor

NRC closes meetings on Vermont Yankee, citing safety concerns
November 5, 2004
BRATTLEBORO, Vt. --Nuclear Regulatory Commission meetings about missing fuel at the Vermont Yankee plant and an engineering inspection are going to be closed to the public.
The meetings, scheduled for Tuesday, were supposed to be open but the NRC decided to close them after safety concerns were raised by Vernon town officials about a large turnout.
Spokesman Neil Sheehan said NRC officials were looking for a larger space in which to hold a public meeting on the engineering inspection at a later date.
The concern about an exceptionally large turnout was evidently triggered by a press release issued by the nuclear power watchdog group, the New England Coalition, encouraging the public to attend the meeting about the engineering inspection.
Sent out by e-mail, the release was forwarded to school or town officials, who then contacted the NRC.
According to Vernon Fire Chief Terrance Parker, the elementary school gym cannot safely accommodate more than 500 people.
"We didn't want to turn people away," said Parker.
There was concern that as many as 1,000 people could show up, overwhelming the town's ability to manage the crowd safely.
On Thursday, after talking with town officials, NRC personnel contacted Peter Alexander, executive director of the coalition, asking for suggestions on an alternative site.
According to Alexander, he made several recommendations, including Keene State College and Landmark College. He also suggested not moving the meeting but setting up an overflow site connected with a video system.
Within hours of that discussion, the decision was made to close the meeting.
"This just shows profound disdain for the people of the area and their elected officials," said Raymond Shadis, technical adviser to the coalition.
Even before Thursday's announcement, there was concern about the meeting as only the preliminary findings from the inspection report are going to be made public. According to Sheehan, that plan has not changed and the initial findings will be posted on the NRC Web site.
Sen. James Jeffords, I-Vt., expressed disappointment in the change of plans.
"The meeting should be public and the potential for a large turnout of interested Vermonters should not deter the NRC from finding an appropriate location so that the meeting can be kept public," said Jeffords.

RETURN DATE: AUGUST 10, 2004 CONNECTICUT COALITION : SUPERIOR COURT AGAINST MILLSTONE, : JUDICIAL DISTRICT OF GERALYN COTE WINSLOW : NEW BRITAIN
CLARENCE O. REYNOLDS, and : AT NEW BRITAIN WILLIAM H. HONAN,
Appellants :

v. :
CONNECTICUT SITING COUNCIL : SEPTEMBER 1, 2004
DOMINION NUCLEAR CONNECTICUT, INC.,
Appellees :

AFFIDAVIT OF APPELLANTS’ EXPERT WITNESS
GORDON R. THOMPSON, PH.D.
IN SUPPORT OF APPELLANTS’ MOTION FOR
STAY OF CONNECTICUT SITING COUNCIL ORDER
PENDING DECISION OF THE APPEAL OR
FOR EXPEDITED CONSIDERATION OF THE APPEAL

I, Gordon R. Thompson, being duly sworn, hereby depose as follows:
Introduction
1. I am over the age of 18 and know the meaning and solemnity of an oath or affirmation.
2. I reside at 27 Ellsworth Avenue, Cambridge, MA 02139. I am the executive director of the Institute for Resource and Security Studies (IRSS), a non-profit corporation whose office is located at 27 Ellsworth Avenue, Cambridge, MA 02139. In addition, I am a research professor at the George Perkins Marsh Institute, Clark University, 950 Main Street, Worcester, MA 01610.
3. I received an undergraduate education in science and mechanical
engineering in Australia and a doctorate in applied mathematics from Oxford University in 1973. I have extensive experience in assessing the safety and security hazards associated with civilian nuclear facilities, and in identifying alternative designs and modes of operation that can reduce a facilityís hazard potential. My work on these matters has been sponsored by local, state and national governments in North America and Europe, and by citizen groups in those regions.
4. This affidavit supports a motion by the Appellants -- the Connecticut Coalition Against Millstone (CCAM) and others -- regarding an order by the Connecticut Siting Council (CSC) in Council Docket #265. The motion requests a stay of the CSC order pending decision on an appeal filed on July 16, 2004, by the Appellants. Alternatively, the motion requests expedited proceedings in this appeal.
5. In its order dated May 27, 2004, the CSC accepted an application by Dominion Nuclear Connecticut, Inc., (DNC) to establish an independent spent fuel storage installation (ISFSI) at the Millstone nuclear power station. At the ISFSI, highly-radioactive spent fuel discharged from the three nuclear reactors at the Millstone station would be held under dry conditions inside storage modules located in the open air. Currently, all of the spent fuel that has been discharged from the Millstone reactors is stored under water in pools. One pool is adjacent to each reactor.
6. A press report dated July 14, 2004, in a Connecticut newspaper stated that construction of the ISFSI had begun. Unless DNC has subsequently stopped work on the project or does so soon, spent fuel may be transferred to the ISFSI before the court has reviewed the merits of the CSC order. Accordingly, the Appellants request a stay of the CSC order or expedited consideration of their appeal. In this affidavit I present facts and arguments showing that it would be prudent, reasonable and protective of the public interest for the court to review the CSC order before any transfer of spent fuel to the ISFSI occurs. I show that the risks that would be incurred by going forward with the ISFSI before the court review has been completed, and before consideration of risk-reducing alternatives, are not purely speculative. The damage that would result from a malicious act or an accident affecting spent fuel at the Millstone station could be irreparable within the local community, the state and beyond. National authorities have warned that an attack on a nuclear power station could occur. I show that options are available for reducing the vulnerability of spent fuel to attack. I show that any cost or inconvenience to DNC or other entities from delaying establishment of the ISFSI until court review is complete or a lower-risk ISFSI plan is adopted would be small compared with the costs to the public arising from a release of radioactive material from inadequately-protected spent fuel at the Millstone station.
7. In setting out facts and arguments that support the Appellantsí motion, I am obliged to comment on the CSC order. The CSC failed to account for three issues that are significant for the safety and security of members of the public in Connecticut and other states. First, the CSC did not account for the potential that a large release of radioactive material to the atmosphere from one or more of the three spent-fuel pools at the Millstone station will occur as a result of an accident or an act of malice or insanity. Second, the CSC did not account for the potential that a large release of radioactive material from the Millstone ISFSI will occur as a result of an act of malice or insanity. Third, the CSC did not account for the potential that spent-fuel storage at the Millstone plant will continue for decades after the Millstone reactors have ceased generating power, thereby causing environmental and other impacts that are not currently anticipated.
8. Each of these three issues involves significant risk to the public. Alternative designs and modes of operation of the Millstone nuclear power station, including the ISFSI, could substantially reduce the level of risk. In not accounting for these three issues, the CSC did not fulfil its responsibilities in two important respects. First, the CSC could have used DNCís application as an opportunity to engage DNC, other interested entities and the public in: (i) identifying options for reducing the risks of spent-fuel storage at the Millstone station; and (ii) assessing the benefits and costs of risk-reducing options. Second, the CSC could, after identifying and assessing risk-reducing options, have required and promoted the implementation of such options. Actions of this type by the CSC could be consistent with the role of the Nuclear Regulatory Commission (NRC) as a licensing agency for activities at the Millstone station. The NRC sets minimum standards for safety and security at nuclear facilities, but does not preclude the introduction of risk-reducing measures that exceed those standards. Moreover, by neglecting the three issues discussed in paragraph 7, the CSC failed to account for the implications of those issues for matters that are clearly within the CSCís sphere of responsibility. These matters include: (i) the capacity, in terms of number of spent-fuel assemblies, of the Millstone ISFSI; (ii) the timing of placement of spent-fuel assemblies into the ISFSI; (iii) the physical configuration of the ISFSI; (iv) the duration of operation of the ISFSI; and (v) the land area occupied by the ISFSI.
9. A stay of the CSC order would allow the CSC and other entities to properly account for the three issues discussed in paragraph 7. Also, a stay would allow the CSC to identify and correct errors in its Findings of Fact dated May 27, 2004. I have identified a significant error, which I discuss later in this affidavit, in the description provided by the Findings of Fact regarding the physical configuration of the spent-fuel-storage modules to be used at the Millstone ISFSI. Any cost or inconvenience arising from staying the CSC order would be insignificant in comparison to: (i) the level of risk that would arise from storing spent fuel at the Millstone station in the manner now envisioned by DNC and the CSC; and (ii) the potential for substantially reducing the level of risk through use of alternative options.
10. In the remainder of this affidavit, I discuss a variety of technical facts and arguments. This discussion is supported by six tables that are part of the affidavit although they appear, for convenience, in Appendix A. Further supporting information is available in three documents that I have authored or co-authored. These documents are provided here in Appendices B, C and D. The documents in Appendices C and D are already part of the record of CSC Docket #265.

The potential for a large release of radioactive material to
the atmosphere from spent-fuel pools at the Millstone station
11. When the Millstone Unit 1 reactor began operating in 1970, nuclear-industry managers and regulatory officials assumed that spent fuel would be removed from each nuclear power station after a few years of storage. This assumption remained operative through the design phase of every commercial nuclear reactor now operating in the United States. Thus, each commercial reactor is equipped with a water-filled spent-fuel pool that was originally designed to store a comparatively small amount of spent fuel, typically a little more than the contents of one reactor core. As a short-term measure, storage of spent fuel in pools has merit. Underwater storage of spent fuel shields workers from radiation and allows the fuel's radioactive decay heat to be transferred to the pool water and then to the environment via heat exchangers.
12. From the late 1970s onward, it became increasingly evident that spent fuel would remain at nuclear power stations for a period of decades. To accommodate the growing inventory of spent fuel, the nuclear industry replaced the original low-density racks in spent-fuel pools with high-density racks. This step substantially increased the risk posed by spent-fuel storage. The original low-density racks had an open-frame configuration, so that spent fuel would be cooled by the natural circulation of air or steam if water were lost from a pool. By contrast, the new high-density racks necessarily have a closed configuration. As a result, loss of water from a pool equipped with high-density racks would cause the spent fuel to overheat. Over a broad range of circumstances, exposed fuel would self-ignite and burn. Once initiated, such a fire would spread throughout the pool and become impossible to extinguish. A large amount of radioactive material would be released to the atmosphere.
13. Water could be lost from a spent-fuel pool as a result of an accident or an act of malice or insanity. In an October 2001 declaration focused on the Millstone Unit 3 pool, I described scenarios that could lead to a loss of water from the pool. Similar scenarios could occur at Millstone Unit 2. Somewhat different scenarios would be applicable to Millstone Unit 1, which differs from the other two units in two significant respects. First, the Millstone Unit 1 reactor has been shut down since 1998. Second, the spent-fuel pool at Millstone Unit 1 is located high above ground level, whereas the Unit 2 and Unit 3 pools are partially below ground level.
14. Various options are available for reducing the risk posed by a high-density spent-fuel pool, including the provision of a system to spray water on exposed fuel. The most effective risk-reducing option, however, would be to restore the pool to its original low-density configuration. Excess spent fuel, for which storage capacity would no longer exist in the pool, would be stored in an on-site ISFSI until it could be transported to another site for burial in a repository or for a further period of above-ground storage. At the Millstone station, restoring the pools to a low-density configuration would require a substantially more rapid expansion of ISFSI capacity than is currently envisioned by DNC and the CSC. They envision expansion only at a rate sufficient to absorb the overflow of spent fuel from the Unit 2 and Unit 3 pools as they reach their capacity limit in a high-density configuration.
The potential for a release of radioactive material from the
Millstone ISFSI through an act of malice or insanity
15. ISFSIs being operated and established in the US, including the Millstone ISFSI, are not designed to resist acts of malice or insanity. By contrast, ISFSIs in Germany are designed to resist anti-tank missiles and other instruments of attack. As an illustration of the vulnerability of the Millstone ISFSI, the canister holding the spent fuel inside each storage module will have a wall thickness of only 0.625 inches. The concrete structure surrounding this canister will have ventilation holes and will therefore have no capability for confining radioactive material. Thus, if the Millstone ISFSI is established with its present design, it will be vulnerable to attack throughout its decades of operation. The inventory of radioactive material in each storage module of the ISFSI will be smaller than the current inventory in a Millstone spent-fuel pool. Nevertheless, the release from an attack on the Millstone ISFSI could be large, with severe impacts on the public.
16. One risk-reducing option for an ISFSI would be to harden the spent-fuel storage modules so that they are more resistant to attack. Another option would be to disperse the modules more widely, to reduce the number of modules that would be damaged in a given attack. The options of hardening and dispersal could be combined.
17. Hardening and/or dispersal of storage modules at the Millstone ISFSI would require that this facility be re-designed. A stay of the CSC order of May 27, 2004, would allow the necessary re-design to occur. The land area required for a Millstone ISFSI with hardening and dispersal is discussed later in this affidavit.
The potential for spent-fuel storage at the Millstone plant to
continue for decades after the Millstone reactors have
ceased generating power
18. The CSC order of May 27, 2004, is predicated on the assumption that the US Department of Energy (DOE) will establish a national repository for high-level radioactive waste at the Yucca Mountain site in Nevada. DOE claims that the repository can be opened in 2010, but that date seems optimistic. DOE envisions that, after the repository is opened, emplacement of spent fuel will occur over a period of 24-50 years, a timeframe that may also prove to be optimistic. Moreover, under present federal law the Yucca Mountain repository will hold no more than 63,000 metric tons of commercial spent fuel. Yet, the cumulative amount of spent fuel to be generated during the current license periods of US commercial reactors is likely to exceed 80,000 metric tons. The granting of license extensions would lead to the production of a substantial additional amount of spent fuel.
19. The preceding paragraph shows that spent fuel will be stored at the Millstone station for a period of decades, even if a repository is established at Yucca Mountain. Some fuel might have to remain in storage at the Millstone station until a second repository is established. In addition, trends indicate that the Yucca Mountain repository may not open. This project faces political opposition in Nevada and along the spent-fuel-transport routes. Also, the project suffers from technical inadequacies.
20. A recent decision by a federal court illustrates the technical inadequacies of the Yucca Mountain project. The court vacated permissible-leakage regulations promulgated by the Environmental Protection Agency and the NRC for the Yucca Mountain repository because these regulations included a compliance period of only 10,000 years. The court determined that this period is not, as the Energy Policy Act requires, "based upon and consistent with" the findings and recommendations of the National Academy of Sciences (NAS).
21. It has been known for at least two decades that a 10,000-year compliance period is inadequate to address the potential leakage of radioactive material from a repository for high-level radioactive waste. This point was confirmed by an NAS panel in 1983. It may prove impossible to re-design the Yucca Mountain repository to demonstrate compliance with leakage limits over a period substantially longer than 10,000 years. In that event, two options would be open to national decision makers. One option would involve termination of the Yucca Mountain project. The second option would require Congress to reverse its previous commitment to NAS recommendations, an action that would feed political opposition to the project. Overall, one can say that the future of the Yucca Mountain project is questionable.
22. In the context of the Millstone station, it would be prudent to assume that spent fuel will remain at the station for decades after the Millstone reactors have ceased generating power. The period of storage could exceed a century. Adoption of this assumption for planning purposes would have two important implications for the design of the Millstone ISFSI. First, the ISFSI would be sized so that it could ultimately accommodate all spent fuel generated at the Millstone station. Second, the design of the ISFSI would reflect environmental and other impacts, including slow-developing safety threats such as corrosion of spent-fuel canisters, that could arise over a period of a century. At present, the NRC licenses dry-storage modules for spent fuel for a period of only 20 years. The NRC is conducting research to assess the performance of the modules over a longer period, up to 100 years.
The threat of attack on the Millstone nuclear power station
23. The Millstone nuclear power station is one of 65 such stations in the United States. National authorities have warned that an attack on a nuclear power station is a realistic possibility. For example, The National Strategy for The Physical Protection of Critical Infrastructures and Key Assets, which was published in February 2003, identifies nuclear power stations as key assets, defined as follows:
"Key assets represent individual targets whose destruction could cause large-scale injury, death, or destruction of property, and/or profoundly damage our national prestige, and confidence".
24. Prominent officials, such as the chair of the National Intelligence Council, Robert Hutchings, have concurred on the security threat to nuclear power stations:
"Targets such as nuclear power plants, water treatment facilities, and other public utilities are high on al-Qaíidaís targeting list as a way to sow panic and hurt our economy. . . . Just this past year, al-Qaíida attacks in Kenya, Saudi Arabia, and Turkey have demonstrated the groupís impressive expertise to build truck bombs, and we are concerned it will try to marry this capability to toxic or radioactive material to increase the damage and psychological impact of an attack. . . . I have already detailed the terrorist threat and feel it is important to point out that according to State Department statistics, more businesses are targeted in terrorist attacks than all other types of facilities combined. US interests both abroad and at home, as well as US citizens working abroad, are prime targets for terrorist groups seeking to damage the US economy and affect our way of life. High-profile facilities such as nuclear power plants, oil and gas production, and export and receiving facilities remain at risk; moreover al-Qaíida and other terrorist groupsí targets and methods may be evolving."
25. It should be noted that the risk of an attack on a nuclear facility accumulates over the facilityís period of operation. In the case of the Millstone ISFSI, that period could be a century or longer. The annual probability of an attack on a key US asset appears to have risen significantly over the past decade. Further increases in future decades cannot be ruled out.
26. An effective attack on a nuclear power station could be accomplished with a variety of instruments, some of which are relatively easy to obtain. As was the case on September 11, 2001, civilian technologies could be adapted for use as weapons. Consider, for example, the use of an explosive-laden smaller aircraft. Flown by a suicidal but competent pilot, such an aircraft could function as a precision-guided cruise missile. In this connection, it is noteworthy that the US General Accounting Office expressed concern, in September 2003 testimony to Congress, about the potential for malicious use of general-aviation aircraft. The testimony stated:
ìSince September 2001, TSA [the Transportation Security Administration] has taken limited action to improve general aviation security, leaving it far more open and potentially vulnerable than commercial aviation. General aviation is vulnerable because general aviation pilots are not screened before takeoff and the contents of general aviation planes are not screened at any point. General aviation includes more than 200,000 privately owned airplanes, which are located in every state at more than 19,000 airports. Over 550 of these airports also provide commercial service. In the last 5 years, about 70 aircraft have been stolen from general aviation airports, indicating a potential weakness that could be exploited by terrorists."
Consequences of a release of radioactive material from
spent fuel at the Millstone station
27. A malicious act or an accident could cause a loss of water from one or more of the spent-fuel pools at the Millstone station. The resulting fire would release a large amount of radioactive material to the atmosphere, creating a radioactive plume that travels downwind. An attack on the Millstone ISFSI could create a similar, although probably smaller, radioactive plume. In either case, as the plume traveled downwind it would deposit radioactive material on buildings, vegetation and other surfaces. The radioactive isotope cesium-137 would be the most radiologically significant isotope in the deposited material. Cesium-137 has a half-life of 30 years and generates intense gamma radiation during its radioactive decay. Being comparatively volatile, cesium-137 is readily released when spent fuel experiences overheating and damage. This isotope accounted for most of the offsite radiation exposure that is attributable to the Chernobyl reactor accident of 1986.
28. Table 4 shows the amount of cesium-137 in spent fuel at the Millstone station. At present, about 120 million Curies of cesium-137 is present in Millstone spent fuel, all of which is stored in the three spent-fuel pools at the site. During a fire in a spent-fuel pool, the fraction of the pool's inventory of cesium-137 that would be released to the atmosphere would be between 10 and 100 percent. A fire in the Unit 2 spent-fuel pool would probably lead to a fire in the Unit 3 pool and vice versa, because the first fire would radioactively contaminate the site to the point where cooling and water makeup could not be provided to the second pool. In some cases a fire could begin in the Unit 1 pool as well. Considering only the Unit 2 and Unit 3 pools, a spent-fuel-pool fire today at the Millstone station would be likely to release 9-90 million Curies of cesium-137 to the atmosphere. For comparison, the 1986 Chernobyl accident released about 2.4 million Curies of cesium-137 to the atmosphere.
29. Some of the consequences of a large, atmospheric release of cesium-137 have been estimated in a recent paper by three of my colleagues. They considered a hypothetical release of 35 million Curies of cesium-137 at each of five nuclear-power-station sites (not including Millstone), and estimated the offsite economic damage. The 5-site average economic damage was found to be about $400 billion. The costs considered were: (i) compensation for loss of contaminated real estate and other property; (ii) relocation costs; (iii) decontamination costs; and (iv) costs of disposing of wastes generated during decontamination. A simple analytic process was used, and the authors relied heavily on a study done for Sandia National Laboratories in 1996. The Sandia study identified factors that could have biased its cost estimates downward, including: (i) neglect of administrative and support costs that could double the cost estimates; (ii) neglect of litigation costs; and (iii) neglect of impacts on downtown business and commercial districts, heavy-industrial areas, and high-rise apartment buildings.
30. My colleagues' paper estimated that, for a release of 35 million Curies of cesium-137, the 5-site average of additional cancer deaths ñ that is, deaths attributable to this release -- would be about 6,000 deaths. These deaths were valued at $4 million each, yielding a cost of $24 billion. If the release also included short-lived radioactive isotopes, as would occur if a reactor core were involved in the release incident, there could be additional cancer deaths.
31. My colleagues considered a set of direct costs arising from contamination of the environment with cesium-137. There would be many additional, indirect costs of a successful attack on a US nuclear power station, including the following five examples. First, the attack would probably lead to temporary or permanent shutdown of other nuclear stations across the nation, leading to additional costs for electricity supply. Second, domestic and foreign markets for US agricultural products and other goods would be depressed by customers' fear of radioactive contamination. Third, the attack would be perceived internationally as a major blow to the US, thereby affecting capital flows, exchange rates, and market valuations. Fourth, the attack would probably lead to a reduction of civil liberties, potentially including a period of martial law, with long-term negative effects on the economy. Fifth, there would probably be large additional US expenditures on homeland security and, potentially, on offensive military operations.
32. A typical spent-fuel-storage module at the Millstone ISFSI would contain 32 fuel assemblies from Unit 2 or Unit 3 of the Millstone station. Suppose that a module contained 32 fuel assemblies from Unit 3, these assemblies having an average age (after discharge from the reactor) of 15 years. From the data in Table 3, one can calculate that this module would contain 1.8 million Curies of cesium-137. The fraction of a module's inventory of cesium-137 that would be released to the atmosphere by an attack on the module would depend upon the nature of the attack. This fraction could be in the range 10-100 percent if the attack caused sustained burning of fuel assemblies. A fuel assembly consists of small pellets of uranium oxide stacked inside thin-walled tubes made of zirconium alloy, which will burn vigorously if ignited.
33. In the presently-planned configuration of the Millstone ISFSI, spent-fuel-storage modules will be located side-by-side in long rows. With that configuration, a single, determined attack on the ISFSI could cause a substantial atmospheric release of cesium-137 from several modules.
Risk-reducing options and their implications for
design and operation of the Millstone ISFSI
34. In this affidavit I have shown that the present approach to storing spent fuel at the Millstone station poses a high level of risk. Options are available for substantially reducing the level of risk. The highest-priority options are: (i) restore the Unit 2 and Unit 3 spent-fuel pools to a low-density configuration, transferring excess spent fuel to an on-site ISFSI; (ii) take the Unit 1 spent-fuel pool out of service, transferring its inventory of spent fuel to an on-site ISFSI; (iii) employ hardening and dispersal at the Millstone ISFSI; (iv) size the Millstone ISFSI so that it could ultimately accommodate the entire inventory of spent fuel discharged from the Millstone reactors over their operating lifetimes; and (v) design the spent-fuel-storage modules for an operating life of a century.
35. In a low-density configuration, the Unit 2 and Unit 3 pools could each be designed to hold spent fuel equivalent to one and one-third reactor cores, with additional capacity for a full-core offload. Given this design, during routine operation the Unit 2 pool would hold 290 spent-fuel assemblies and the Unit 3 pool would hold 258 assemblies. Thus, 798 assemblies now in the Unit 2 pool would have to be transferred to the ISFSI, together with 396 assemblies from the Unit 3 pool. This should be done over the shortest possible time period, which could be about 2 years. Accommodating 1,194 (798 + 396) spent fuel assemblies in dry-storage modules holding 32 assemblies per module would require the deployment of 38 modules. Assuming that the Unit 2 and Unit 3 reactors continued to operate, additional modules would be required on a continuing basis to accommodate the overflow of spent fuel assemblies from the Unit 2 and Unit 3 pools as assemblies were discharged into those pools from the reactors.
36. The Unit 1 pool now contains 2,885 spent fuel assemblies. Accommodating these assemblies in dry-storage modules holding 61 assemblies per module would require the deployment of 48 modules.
37. As shown in Table 5, hardening and dispersal of the Millstone ISFSI would require a substantial increase in the land area occupied by the ISFSI. If the ISFSI were sized to accommodate the entire inventory of spent fuel that could be discharged from the Millstone reactors over their operating lifetimes, Table 6 shows that 208 dry-storage modules would be required. With hardening and dispersal, these modules would occupy a land area of 16.8 acres. The calculations underlying Table 6 do not incorporate conservatisms. DNC, presumably with the incorporation of conservatisms, originally designed the Millstone ISFSI to accommodate 234 modules. This would be an appropriate size for design purposes. Assuming hardening and dispersal, and extrapolating from Table 6, one finds that an ISFSI designed to accommodate 234 dry-storage modules would occupy a land area of 18.9 acres. For comparison, note that the Millstone site has a total area of 520 acres, within which is a Protected Area occupying 49.3 acres. Thus, there appears to be sufficient space on the site for an ISFSI occupying a total area of 18.9 acres. Dry-storage modules might be placed at more than one location on the site.
38. At present, there is no regulatory basis upon which to design spent-fuel-storage modules for an operating life of a century. Thus, attempting to satisfy this design requirement for an ISFSI built in the near term would involve an interim approach in which the best available knowledge and conservatisms would be used. Later, when an appropriate regulatory basis became available, re-packaging of spent fuel into new canisters might be required. The design of the Millstone ISFSI should allow for the possibility of re-packaging.
Current events that support the arguments made in this affidavit
39. Various current events support the arguments that I have made in this affidavit. Selected events are briefly discussed in the two following paragraphs.
40. Publications by other authors and me helped to influence Congress to request from the NAS an independent, classified study on the security of spent-fuel storage. Congress was motivated to take this action by concern that the NRC was not properly considering the threat to spent fuel. The study began in January 2004, and it is said that a classified report was provided to Congress in late June or early July 2004. Congress has requested the NRC to "take recommendations of the final NAS report seriously and to take actions to address these recommendations at the earliest possible date". In a letter dated July 29, 2004, to its power-reactor licensees, the NRC informed the licensees about "measures that can mitigate potential damage to spent fuel in a SFP [spent-fuel pool] caused by a terrorist attack or other initiating event". The measures were described in an attachment to the NRC's letter, and this attachment has not been published.
41. In April 2004 the Holtec company, a vendor of dry-storage modules for spent fuel, asked the NRC to provide expedited generic approval of partial-underground placement of modules. This system would employ the Holtec HI-STORM 100 module. The top of the module would project about 2 feet above ground. Holtec has described this system as offering "the next level of protection against terrorist attacks".
An error in the CSC Findings of Fact
42. In paragraph 9, I state that a stay of the CSC order would allow the CSC to identify and correct errors in its Findings of Fact dated May 27, 2004. Here, I describe such an error. In their Appendix C, the Findings of Fact provide an illustration of the NUHOMS dry-storage module that will be used at the Millstone ISFSI. Yet, a newer and quite different design of module is actually to be used at the Millstone ISFSI, as is evident from Drawing No. 10 in Attachment 5 to DNC's application. The CSC appears to be unaware that use of the new design could have safety and security implications. The CSC's technical understanding of the properties of the NUHOMS module appears to derive from a version of the NUHOMS Final Safety Analysis Report that does not describe the new module design. I have found no evidence that the CSC has confirmed that the new module design has been approved by the NRC.
Urgency of establishment of the Millstone ISFSI
43. The CSC Findings of Fact state that, without establishment of the Millstone ISFSI, Millstone Unit 2 would lose the capability for a full-core discharge after the Spring 2005 refueling outage. Maintaining such a capability is prudent for an operating reactor. Thus, a stay of the CSC order might delay restart of the Millstone Unit 2 reactor after the Spring 2005 outage. This delay might create some cost and inconvenience to DNC and other entities. Interruption of electricity supply to Connecticut consumers is not, however, a likely outcome. A CSC publication shows that Connecticut's expected peak electricity demand in 2005 is 6,716 MW, while the expected supply of electricity is 10,310 MW. From Table 1 of this affidavit, it can be seen that Millstone Unit 2 has a rated electrical output of 871 MW. Accordingly, it is likely that Connecticut's peak demand in 2005 could be met with a prudent margin of supply if Millstone Unit 2 were unavailable.

Conclusions
44. In accepting DNC's application to establish an ISFSI at the Millstone nuclear power station, the CSC has failed to account for three issues that involve significant risk to the public. Adoption of alternative designs and modes of operation at the Millstone station, including the ISFSI, could substantially reduce the level of risk. Current events show that relevant risk-reducing options are receiving serious consideration within Congress and the nuclear industry. A stay of the CSC order of May 27, 2004, would allow options of this kind to be assessed and implemented in the context of the Millstone station. Any cost or inconvenience arising from the stay would be insignificant in comparison with: (i) the level of risk that would arise from implementation of the CSC order; and (ii) the potential for substantially reducing that risk.

I solemnly affirm that the foregoing statement is true to the best of my knowledge and belief.

Signed: ---------------------------------------------- Date: September 1, 2004
Gordon R. Thompson

APPENDIX A
TABLES FOR THE AFFIDAVIT

On the following pages are six tables that are part of this affidavit. These tables are discussed in the body of the affidavit.
Table 1
Selected Characteristics of the Three Units at the Millstone Nuclear Power Station
CharacteristicUnit 1Unit 2Unit 3Rated power 2,011 MWt2,700 MWt
871 MWe3,411 MWt
1,130 MWeNumber of fuel assemblies in reactor core when operating580217193Year when commercial operation began197019751986Year when operation ceased1998----Year when present operating license expires--20152025Inventory of spent fuel assemblies in December 20032,8851,088654Capacity of spent-fuel pool (number of assemblies)?1,3461,779Schedule for discharging spent fuel--approx. 1/3 of assemblies in core are discharged every 18 monthsapprox. 1/3 of assemblies in core are discharged every 18 months
Notes:
(a) Rated power is expressed as MW-thermal (MWt), the power released in the reactor core by nuclear fission, and MW-electric (MWe), the electrical power sent to the transmission grid.
Sources: Prefiled testimony to Connecticut Siting Council by Stephen E. Scace, 8 December 2003; NRC website, accessed 24 April 2002 and 26 August 2004; Jay R. Larson, System Analysis Handbook, NRC publication NUREG/CR-4041, November 1985.

Table 2
Selected Characteristics of Spent Fuel at the Millstone Nuclear Power Station: Present Data and Estimates for the Future
CharacteristicUnit 1 FuelUnit 2 FuelUnit 3 FuelInventory of spent fuel assemblies in December 20032,8851,088654Average post-discharge age of spent fuel in December 200318 yrs13 yrs7 yrsInventory of spent fuel assemblies when present operating license expires--1,667
(in 2015)1,598
(in 2025)Average post-discharge age of spent fuel when present operating license expires--19 yrs
(in 2015)18 yrs
(in 2025)Inventory of spent fuel assemblies on completion of a 20-year license extension--2,631
(in 2035)2,456
(in 2045)Average post-discharge age of spent fuel on completion of a 20-year license extension--29 yrs
(in 2035)28 yrs
(in 2045)
Notes:
(a) Underlying data are from Table 1.
(b) The first discharge of spent fuel from each reactor is assumed to have occurred three years after commencement of commercial operation.
(c) Inventory estimates for the future assume that 1/3 of the fuel assemblies in the core of an operating reactor are discharged every 18 months.
(d) It is assumed that no spent fuel is removed from the Millstone site during the time period covered by this table.

Table 3
Amount of Cesium-137 in Spent Fuel Discharged from Selected Reactors
ReactorAmount of cesium-137 in
each spent fuel assembly when discharged from reactor
(Curies)Millstone Unit 117,000Ginna56,000Millstone Unit 255,000Millstone Unit 379,000
Notes:
(a) Data for Millstone Unit 1 and Ginna are from: V. L. Sailor et al, Severe Accidents in Spent Fuel Pools, in Support of Generic Safety Issue 82, NRC publication NUREG/CR-4982, July 1987.
(b) Millstone Unit 1 data are for spent-fuel-batch number 11, consisting of 167 assemblies with an average burnup of 30 GW-days per MTHM.
(c) Ginna data are for spent-fuel-batch number 16, consisting of 24 assemblies with an average burnup of 46 GW-days per MTHM.
(d) The Ginna reactor has a rated power of 1,520 MWt and its core contains 121 fuel assemblies; these data are from the source cited in note (a). Equivalent data for the Millstone Unit 2 and Unit 3 reactors are provided in Table 1.
(e) Cesium-137 amounts for Millstone Units 2 and 3 are estimated from the Ginna data according to proportions of rated power and number of fuel assemblies per core.

Table 4
Amount of Cesium-137 in Spent Fuel at Millstone Nuclear Power Station: Present Data and Estimates for the Future
DateAmount of cesium-137
(millions of Curies)Unit 1 FuelUnit 2 FuelUnit 3 FuelTotalDecember 2003324444120201525596815220451259102173
Notes:
(a) It is assumed that each of the Millstone Unit 2 and Unit 3 reactors operates through its existing license period and for a subsequent 20-year period.
(b) It is assumed that no spent fuel is removed from the Millstone site during the time period covered by this table.
(c) Spent-fuel inventories are as shown in Table 2 or are calculated using the same methodology. Thus, the Unit 1 spent-fuel inventory would remain constant at 2,885 assemblies, with an average age of 30 yrs in 2015 and 60 yrs in 2045. The Unit 2 spent-fuel inventory in 2045 would be 2,631 assemblies, as in 2035, but the average age of the fuel would increase to 39 years. The Unit 3 spent-fuel inventory in 2015 would be 1,169 assemblies, with an average age of 13 years.
(d) Amounts of cesium-137 are calculated using the values provided in Table 3, correcting for radioactive decay with a half-life of 30 years.

Table 5
Land Area Occupied by NUHOMS Spent-Fuel-Storage Modules at the Millstone Nuclear Power Station: the Arrangement Planned by DNC and an Alternative Arrangement with Hardening and Dispersal
Type of areaLand area occupied per module
(square feet)Arrangement planned by DNCAlternative arrangement with hardening and dispersalDirect footprint of module (and hardening structure/berm)1901,710Remainder of ISFSI area4551,820 Total6453,530
Notes:
(a) For the arrangement planned by DNC, each module is assumed to have a direct footprint area of 8 feet 5 inches by 22 feet 7 inches, reflecting a long single-row arrangement with rear shield walls; these dimensions are from DNC drawing number DWG-10, 19 May 2003.
(b) The total ISFSI area planned by DNC, for 135 modules, is about 2 acres (87,120 square feet); see paragraph 46 of CSC Findings of Fact, 27 May 2004.
(c) In the alternative arrangement, modules would be located in groups of two, each group would be surrounded by a hardening structure/berm, and the average distance between modules would increase. It is assumed here that the combined direct footprint area of the modules plus hardening structures/berms would increase by a factor of 9 from the equivalent area for the DNC arrangement, and the remainder of the ISFSI area would increase by a factor of 4, both on a per-module basis.

Table 6
Selected Characteristics of Spent-Fuel Storage at the Millstone Nuclear Power Station: Estimates for the Year 2045
CharacteristicsUnit 1 FuelUnit 2 FuelUnit 3 FuelTotalInventory of spent fuel assemblies2,8852,6312,4567,972Number of NUHOMS spent-fuel-storage modules488377208Land area of ISFSI using an arrangement of the type planned by DNC0.7 acres1.2 acres1.1 acres3.0 acresLand area of ISFSI with hardening and dispersal3.9 acres6.7 acres6.2 acres16.8 acres
Notes:
(a) It is assumed that each of the Millstone Unit 2 and Unit 3 reactors operates through its existing license period and for a subsequent 20-year period.
(b) It is assumed that no spent fuel is removed from the Millstone site during the time period covered by this table, and that all spent fuel on the site in 2045 is stored in an ISFSI employing NUHOMS modules.
(c) Spent-fuel inventories are as shown in Table 2.
(d) It is assumed that each NUHOMS module contains 61 BWR (Millstone Unit 1) fuel assemblies or 32 PWR (Millstone Units 2 and 3) fuel assemblies; see page 9 of the DNC application to the CSC, 25 August 2003.
(e) ISFSI land areas per NUHOMS module are from Table 5.

Patricia Daddona, "Storage work under way at Millstone", The Day, July 14, 2004.
The three appended documents are: (i) Appendix B: Declaration of 31 October 2001 by Dr. Gordon Thompson in Support of a Motion by CCAM/CAM before the Atomic Safety and Licensing Board, US Nuclear Regulatory Commission; (ii) Appendix C: Robert Alvarez, Jan Beyea, Klaus Janberg, Jungmin Kang, Ed Lyman, Allison Macfarlane, Gordon Thompson, Frank N. von Hippel, "Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States", Science and Global Security, 11:1-51, 2003; and (iii) Appendix D: Gordon Thompson, Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security (Cambridge, MA: Institute for Resource and Security Studies, January 2003).
Declaration of 31 October 2001 by Gordon Thompson, op cit.
Alvarez et al, 2003, op cit.
Alvarez et al, 2003, op cit.
Transnuclear West, Final Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 6, October 2001, page 1.2-7.
Thompson, January 2003, op cit.
It is possible that some spent fuel will be removed from the Millstone site for further above-ground storage at another location. This possibility is not discussed in the CSC Findings of Fact, May 27, 2004.
Thompson, January 2003, op cit, pages 12-13.
Nuclear Energy Institute versus Environmental Protection Agency, US Court of Appeals for the DC Circuit, decided on July 9, 2004.
The NAS recommendations are in: Commission on Geosciences, Environment and Resources, National Research Council, Technical Bases for Yucca Mountain Standards (Washington, DC: National Academies Press, 1995).
Waste Isolation Systems Panel, Board on Radioactive Waste Management, National Research Council, A Study of the Isolation System for Geologic Disposal of Radioactive Wastes (Washington, DC: National Academy Press, 1983).
The White House, The National Strategy for The Physical Protection of Critical Infrastructures and Key Assets (Washington, DC: The White House, February 2003, page 7).
Robert L. Hutchings (chair, National Intelligence Council), speech to the International Security Management Association, January 14, 2004.
Thompson, January 2003, op cit.
Gerald L. Dillingham (US General Accounting Office), Testimony before the Committee on Commerce, Science and Transportation, US Senate, September 9, 2003, page 14.
Table 4 draws upon information in Tables 1 through 3. The calculations and sources underlying each table are described in the accompanying notes.
Alvarez et al, 2003, op cit.
From Table 4, the combined present inventory of Unit 2 and Unit 3 spent fuel at the Millstone station is 88 million Curies. 10-100 percent of this amount is 8.8-88 million Curies.
Jan Beyea, Ed Lyman, Frank von Hippel, "Damages from a Major Release of 137Cs into the Atmosphere of the United States", Science and Global Security, 12:125-136, 2004.
See Table 6.
See Table 1.
The spent fuel with the greatest age after discharge would be transferred to the ISFSI.
CSC Findings of Fact, May 27, 2004, paragraph 30.
CSC Findings of Fact, May 27, 2004, paragraphs 18 and 19.
Washington staff of Inside NRC, "NRC instructed to hire NAS for spent fuel pool hazards study", Inside NRC, 17 November 2003, pages 1, 12-13.
Jenny Weil, "NAS study to urge NRC to step up spent fuel protections", Inside NRC, 28 June 2004.
Ledyard B. Marsh (NRC Office of Nuclear Reactor Regulation), letter to Holders of Licenses for Operating Power Reactors as Listed in Enclosure 1, July 29, 2004.
Maureen Conley, "Holtec to ask NRC to approve underground design for dry storage facility", Nuclear Fuel, 26 April 2004, pages 1 and 11.
Transnuclear West, Final Safety Analysis Report, Revision 6, October 2001, op cit.
CSC Findings of Fact, May 27, 2004, paragraph 45.
Connecticut Siting Council, Review of the Connecticut Electric Utilities' Ten-Year Forecasts of Loads and Resources, 2003, Table 1 (status quo generation scenario).
Affidavit of Gordon R. Thompson
Page PAGE 39

UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the Matter of :
DOMINION NUCLEAR CONNECTICUT, INC. :Docket Nos. 50-336-LR,
50-423-LR
(Millstone Nuclear Power Station, :
Units 2 and 3) :ASLBP No. 04-824-01-LR
AFFIDAVIT OF CYNTHIA M. BESADE
I, Cynthia M. Besade, do hereby declare as follows:
I am above the age of eighteen (18) years and I believe in the obligation of
an oath.
2. From the age of three to age twenty (1963ñ1979), I resided with my family at 21 Fifth Avenue in Waterford, Connecticut, a location which is within two miles of the Millstone Nuclear Power Station.
My father, Joseph H. Besade, was employed at the Millstone Nuclear
Power Station from 1973 until 1993 as a nuclear pipefitter.
In such capacity, my father was exposed at the Millstone Nuclear Power
Plant workplace to ionizing radiation created as a byproduct of nuclear fission at the facility.
On or about May 2003, my father was diagnosed with cancer.
From May 2003 until August 2003, my father underwent treatment for his
cancer.
Despite such treatment, my fatherís cancer spread rapidly and on August
16, 2003, my father succumbed to the disease.
My fatherís treating physician, who was affiliated with the New London
Cancer Center and the Lawrence & Memorial Hospital, told me in August 2003 that she believed that what my father had related to her as follows was correct:
That my fatherís cancer was directly related to his workplace exposure at Millstone;
That my father was exposed to high levels of radioactivity in certain areas of the facility; and
That the protective clothing and lead blankets issued to workers, including my father, to prevent harm to their health from exposure to radiation were inadequate to the purpose.
I have been personally acquainted with many of my fatherís former co-
workers at Millstone.
I am aware that seven (7) of his nuclear pipefitter co-workers succumbed
to cancer before he became the eighth.
When I was growing up in Waterford, I recall promoters of the Millstone
Nuclear Power Station providing assurances to the community that the facility would be safe and that it would provide cheap, clean and non-polluting electricity. Each of these representations has proved to be false.
I have been personally acquainted with many families living in the
Waterford, East Lyme and Niantic and surrounding communities.
I have been personally acquainted with many individuals who have worked
at Millstone and/or resided in the community surrounding Millstone who have died from cancer and cancer-related illnesses.
I have been personally acquainted with many individuals who have
worked at Millstone and/or resided in the community surrounding Millstone who have been diagnosed with cancer, have undergone treatment for cancer and presently survive.
I am also indirectly acquainted with individuals who have worked at
Millstone and/or resided in the community surrounding Millstone who have died from cancer and cancer-related illnesses or who have undergone treatment for cancer and presently survive.
I attach hereto a list of the individuals referenced above in paragraphs 13,
14 and 15. (Other than my father, the names of all others are not being revealed here although their identities are retained by me).
I hereby swear that the information provided herein is true to the best of my knowledge, information and belief under penalty of perjury.
_________________________
Cynthia M. Besade
Dated: August 9, 2004

Millstone Community Cancer Victims
Personally Known
Joseph H. Besade Fifth Ave. Waterford worker/community
Metastatic Lung Cancer Deceased/Aug. 16, 2003
Age 66

Male Daniels Ave. Waterford community
Brain cancer Deceased/ 1980?
Age 50?
3. Male Third Ave. Waterford worker/community
Brain cancer Deceased/year?
Age 35?
4. Male / Fifth Ave. Waterford community
Age 65 diagnosed w/Lung cancer/ survivor .......2003 Fall Diagnosed w/ Brain Cancer /survivor
5. Male/Doctor practice was located on Main St. Niantic community/1970' &80's
Blood cancer/unknown type status unknown/ 1996?1997?
Age 70?
6. Male Flanders Road/Rt. 161 Niantic community
Throat cancer Deceased/ June 22, 2003
Age 72
7. Male 33 Roxbury Road Niantic community/parent of #8.
Metastatic Liver cancer Deceased/ 1979?
Age 60?
8. Male 33 Roxbury Road Niantic 20 yr.worker/community
Brain tumor diagnosed 1986/29 years of age then. Survivor/disabled
Current age 48
(note: this begins the NU Unit 1maintenance dept. )(personnel that handled contaminated waste) where three people developed brain cancer within the same timeframe. NU abruptly closed this department and dismissed the employees in Jan. 1994) NU had them to sign off to not file suit against them (NU offered and paid $ for sign off) to #8, 9, + 10
9. Male unknown address worker/community
Brain cancer Deceased / 1998?
Age between 30 and 40
10. Female Shennecossett Road Groton worker/community
Brain cancer/diagnosed 1985 Deceased/1997
11. Female Miss Vans Court Waterford Community
Leukemia Deceased/1995
Age 56
12. Male Tenth Ave. Waterford Community
Blood cancer/Type? Deceased/1976?
Age 18
13. Male Willets Ave. Waterford Community
Brain cancer Deceased/1982
Age 30?14. Male Oswegatchie Hills Road Niantic worker/community
cancer? unknown type Deceased/2000
Age 70?
15. Male Unknown address/Professor @Three Rivers community
Brain cancer c. college Deceased/2004
Age 30 something
16. Male Niantic River Road Waterford community
Brain Cancer Deceased/1981
Age 45? Taught Science at Waterford High
17. Male Niles Hill Road Waterford carpenter worker/community
Lymphoma Survivor
Age 30 something @ diagnosis 1997?
18. Male Monroe Street Waterford community
Lymphoma Deceased/1986? 1987?
Age 50 something
19. Female Monroe Street Waterford community
Lymphoma Deceased/1986? 1987?
Age unknown #18's mother-in-law
20. Female/child Mullen Hill Road Waterford community/father was worker
Bone cancer Leg amputated/1971 or so? Survivor
Age 11?
21. Male/teen unknown address/Sunset Dr. Waterford
Tumors in Spinal column Deceased /1985
Age 19
22. Male Tiffany Ave. Waterford community pancreatic/liver cancer? Not real sure though Deceased /1987
Age 48?/50?
23. Female Lloyd Road Waterford community
Liver cancer Deceased /1980
Age 25?
24. Male Shore Road Waterford community
Liver cancer? Deceased /1977
Age 50 something? (Parent to #25)
25. Male Shore Road Waterford carpenter worker/community
Brain cancer (son of #24) Deceased / Jan. 1987
Age 31
26. Female (mother of # 24) Roselund Hill Uncasville community(summered on Jordan Cove)w/24&25
Brain cancer Deceased/1986
Age 70?
27. Male child Fifth Ave Waterford community
leukemia Status unknown
Age of diagnosis 2 or 3 years28. Female child Fifth Ave Waterford community
spinal tumors (attended Southwest School) Deceased / 1975?
29. Female Shore Road Waterford community
Breast Cancer/Double mastectomy Survivor
Age: 25?

30. Female 15 Lamphere Road Waterford community
Leukemia Deceased / 1979? 1980?
Age 18?
31. Female Gay Hill Road Uncasville community
pancreatic cancer Deceased/ 1982?
Age 60?
32. Female Gay Hill Road, Uncasville community
Ovarian cancer/ Deceased/1995? unknown onset of disease maybe 1993
Age 35
33. Male/ Vauxhall Steet ext. Waterford community
Lung cancer/deceased/2000
Age 65?
Female/ unknown location Wtfd./NL community
Breast cancer/ relative of above #33
Deceased/ 2001
Age unknown ? 60 guessing
Female/ Niantic community
Breast cancer/ Deceased/ 2000? Or 1999?
Age 70?
36. Male/ Great Neck Road, Waterford community/ nursery farmer
Cancer origin unkown? Deceased July 2004
Age 71
Male/ George Street Waterford/ then Spithead Road where he died this spring 2004/ Seaside Regional DMR/Director of Camp Harkness
Age 54
Female/ Spithead Road Waterford community Age 65? Breast cancer / survivor
Male/ husband of # 37 Age 65? (Both relocated to Florida, both were recently diagnosed) Lymphoma
39. Female/ The Strand, Waterford community
Breast cancer/ 1970's or early 80's survivor (another relocated to Florida)
40. Female/ a street off Oswegatchie Road, Waterford community (sister of my dad's neighbor)
Age 40? Breast Cancer/ Deceased 1985 or so? Can't exactly remember the date
41. Female/ Niantic River Road Waterford community/ worked in downtown Niantic owned a children's clothing store 1970's through 1989 or so?
Age 50? Breast Cancer...good friend of Carols Deceased/1998? Not real sure on this date of death but close
42. Female/teen 17 at onset Rope Ferry Road, Waterford community/student
Bone cancer/ leg amputated 1979? Survivor
43. Male/ Logger Hill/Rope Ferry Road Waterford/ then Niantic community
Age 60? Lung Cancer / Deceased 2000
44. Male/ Quaker Hill Waterford
Lung Cancer/ Age 58? Deceased 1990?
45. Male/ Clark Lane Waterford community
Age 45...diagnosed w/leukemia age 30 something survivor

46. Male/Clark Lane Waterford community
Age unkown maybe 50 something.....Father to # 45. Deceased / late1980's/early 90's Cancer type unknown
47. Female/ Dainels Avenue Waterford community (sister of Dad's neighbor same family as listed in # 40.)
Breast Cancer/ Deceased 2003 less than a month before Joe.
48. Female/ Niantic River Road Waterford community
Cancer type can't remember.....Deceased 1980's Mother in law to the # 49
Female/ Niantic River Road (NOT THE SAME HOUSE BUT THE SAME FAMILY)
Breast Cancer real aggressive type inflammatory 1990 survivor
Age 35?
50. Female/ Gallup Lane Waterford community/wife of L&M Hospital. President
Breast cancer 1975 Deceased same yr.
Age 35?
51. Female/ Oswegatchie Waterford community/wife of dentist
Breast cancer 1974 1975? Deceased same yr.
Age 35?
Indirectly Acquainted
52. Female Seabreeze Drive Waterford
Breast Cancer Deceased 2003 Age 83
53. Male, Seabreeze Drive Waterford
Colon Cancer Deceased 2001
54. Male Seabreeze Drive Waterford
Liver Cancer Deceased 2003
55. Female Seabreeze Drive Waterford
Breast Cancer 2000 Survivor
56. Female Crescent Beach East Lyme
Age 10 at exposure, now 26 Thyroid cancer survivor
57. Female Niantic
Thyroid Cancer 2000 (?)
58. Female Niantic
Breast cancer (2000?)
59. Female Groton Long Point
Breast Cancer 1999 Survivor
60. Female Waterford
Ovarian Cancer, high school sophomore, survivor
61. Female Shore Road Waterford
Cancer of unknown origin survivor
62. Female Mystic
Breast cancer 50s survivor
63. Female Mystic
Age 3 Cancer of unknown type
64. Male Niantic
Brain cancer (2002?)
65. Male Waterford
School age childhood leukemia 2003
66. Niantic ñ Cluster of cancer cases on Bluff during 1990s
57. Female Black Point Niantic
Cancer of unknown type (2003?)

Joe's Final Plea
As Related to Cynthia M. Besade
August 14, 2003(Note: My dad, Joseph H. Besade, gave 8 years of his life, countless hours and endless energy taking on one of the largest and most dangerous polluters in our midst ñ the Millstone Nuclear Power Station in Waterford, Connecticut. My dad died of metastatic lung cancer on August 16, 2003. His physicians associated the disease with my dad's exposure to radiation as a nuclear pipefitter at Millstone from 1973 until 1993, when he was fired as a whistleblower for reporting and acting on safety concerns. My dad worked all those years at Millstone to provide for his family and, after he left Millstone, to protect his community and neighbors from the dangers he learned about first-hand at Millstone. My dad was a private working class citizen who put himself on the line for those he loved and those he never knew to make life safer for us all by exposing the lies. He tried to make them stop lying and have the truth be told. My dad can't do that for us anymore. Now it's up to us to do it.
The following is a compilation of thoughts my dad left behind for me, as his life forces ebbed, to share with you, the community of humankind he loved.)When something's wrong, it's our responsibility to make it right.
Joe was told while working in the nuclear industry: He who has the gold makes the rules and the one with the most money wins. Joe discovered otherwise. He became enlightened. He learned that you can bring about change if you really desire to. There is a chance.
Stop lying and tell the truth.
Releasing radiation from the radiation stack and the vents so that it is dispersed throughout the community is a trespass and a crime against the community.
When Millstone releases radioactive gases to the environment ñ either as scheduled releases or in an accident ñ its public relations team always says the incident posed no threat to the people in the surrounding community. The same statement accompanies the admission that lost radioactive spent fuel rods are still missing. Don't believe them. They're lying. Don't buy the propaganda any more.
Radiation kills. Any dose of radiation is an overdose. îLow levelsî of radiation escape from even the ìsafestî reactors (Millstone is not in that category.) Lethal particles and rays ñ why do you think they attempt to shield you with lead during x-rays? It took decades for the medical profession to warn about the dangers of x-rays. The debate is over: even ìlow-doseî dental x-rays cause measurable bodily harm.
Just because you can't see it (the radiation), smell it or taste it does not mean you're not taking it into your body. The air you breathe, the water you drink are contaminated. You just don't know it's there. Even without catastrophic accidents ìnormalî reactor operations are murderous.
Reactors can kill.
Work to protect your body from any unnecessary doses, especially from Millstone. Go ask Dominion for evidence that shows otherwise. Check their history.
License renewal for nukes? Nuclear reactors become old and brittle because the radiation degrades the metal. They suffer ìreactor arthritis.î The huge pressure vessels that contain the super heated core become embrittled, and they can shatter when flooded with emergency cooling water.
We are seconds from annihilation. How would we ever get over that! They never had a plan. The plan they have is fake, hollow, K-2, evacuation. The plant is a creature from another time. They built the giant power station that undergoes nuclear chain reactions while you sleep.
Now that disaster is on our minds, remember money wins out every time. No one stopped to think about the people and how they would survive. No one stopped to think about the babies.
Don't lay down. Don't go with the flow. Don't let the corporation roll over you.
People downwind - all of you - live every day under an apocalyptic cloud. In the shadow of Millstone with its radioactive emissions and waste - a prime target of terrorism.
Mother earth is crying out. This is the battle. We cannot lose. Only if you respect your own life can you respect the life of another.
It is easier to ignore the threat posed by the nuclear power industry if there is nothing you feel responsible for. Fight to protect the unborn. Children should be allowed to enjoy their God-given right to good health and a long life. This is not happening here. We're burying them instead. This is too painful for parents to survive. Help them. No one stops to think about the babies or how they would survive.
Each person should do what they can to stop this madness. Don't surrender to the tremendous feeling of hopelessness. You have no choice but to fight. Nuclear power scares me to death. I'm not sure they ever knew what they were doing. They had absolutely no plan and did not think ahead. Things like handling waste, protecting the people.
Dominion Nuclear has had more control than you know in running the government and I don't think we want that. Don't let them take the chance with our lives any longer.
The government departments in charge of monitoring the operations for our protection in enforcing the long-fought-for laws, Clean Water Act, etc., aren't doing so. We can change that. Anything is possible. A Dominion official said this industry is just business. Success is blowing the whistle and telling the truth.
We are drowning in radioactive trash. The stuff is so dangerous. Invisible specks can give you cancer. It is so hot and corrosive it eats through every substance known. It stays radioactive so long it has to be isolated from living things for as long as 250,000 years. No plan was considered. Millstone created an astronomical amount of radioactive garbage which can never be 100 per cent isolated and it sits idling in your backyard. The spent fuel pool is full. They want dry cask storage ñ a new terrorist target. They'll create a target for terrorist attack for which there is no defense. They'll force upon you a nuclear waste dump with room for expansion in your backyard.
This is a realistic fear since we all felt what happened on September 11.
Lost fuel rods remain unaccounted for. They violated our safety and lied for years. They got a slap, a fine.
In 1978, there were 22 nonscheduled radioactive releases which they tried to hide from everyone. Governor Grasso found out. It was too late. The damage was done.
At TMI, officials denied they experienced a meltdown. They lied to the people at the time it was happening. The same officials had to admit that nearly all of the core had melted. 25 years later, 2400 families devastated by TMI's fallout are still awaiting compensation. The company is waiting for them to die and go away. Please make them take their atomic poison power away. If you care enough, join together to raise the consciousness of this community. It is in your best interest.
Once sold as too cheap to meter, nuclear power has become history's most expensive technological fiasco and we paid for it. With our money and our lives. Because when it comes to people's safety you know money really wins out every time.
High in cost and unreliable as a source of electricity, not to mention unsafe, under normal business experience, when a business fails stockholders pay. But with the nuclear industry, it's consumers who pay. In other words, it's corporate welfare. We must now pay for the worst technological failure in all industrial history.
Question: Will we let them get away with it?
Dominion disguises its acts of generosity. It's make-believe. They're pulling the smoke and mirrors trick. They're sweet-talking you to distract you to make you feel good about them and all the while they're irradiating you and causing genetic mutations in your kids and grandkids.
Please listen! Take action! Your life and the lives of your children and their children depend on it. I know.

MILLSTONE RADIATION EMISSIONS LINKED TO WORKER DEATHS AND HIGH CANCER INCIDENCE IN COMMUNITY For Immediate Release August 15, 2004
Contact: Nancy Burton 203-938-3952/203-545-9252

Eight pipefitters at the Millstone Nuclear Power Plant in Waterford have died prematurely of cancer and related illnesses over the past two decades.
The nuclear facility's site maintenance department was eliminated when three workers in that unit who dealt with radiological waste were diagnosed with brain cancer in 1994. Two have since died.
These and other reports of cancer mortalities and illnesses among former workers at Millstone and residents of the surrounding areas were presented in a sworn statement last week to the U.S. Nuclear Regulatory Commission by Cynthia M. Besade.
Besade is a daughter of longtime anti-Millstone activist Joseph H. Besade. Her father died on August 16, 2003 after battling metastatic lung cancer, a disease his doctors associated with his workplace exposure at Millstone from 1973 to 1993, according to Besade.
Joseph H. Besade was fired as a whistleblower for raising safety issues. He became a vocal advocate for closure of the nuclear facility because he believed it was a threat to the public health and safety.
Besade's daughter presented the NRC with a list of more than 67 individuals she has known, directly and indirectly, in the communities surrounding Millstone who have died from cancer or are undergoing treatment for cancer. She grew up in Waterford less than two miles from Millstone.
Many of the cancers on Besade's list involve children; the list includes a high student in Waterford who was recently diagnosed with ovarian cancer.
"No level of exposure to radiation is safe," Besade said. "Any dose is an overdose."
.† "To the extent that exposure to radioactivity from Millstone was responsible for my father's death and the deaths and illnesses of my friends and neighbors, these deaths and illness were avoidable," said Cynthia M. Besade.
"If these deaths and illnesses were avoidable, the role of Millstone is unforgivable," she said.
The NRC calculates collective radiation doses contribute to 12 cancer deaths for each 20-year term a nuclear reactor operates, providing there are no accidents, or need for "emergency" releases, according to Agnes Reynolds, a registered nurse in Wethersfield.†
Besade cited reports filed with the NRC by expert witnesses for the Connecticut Coalition Against Millstone last week to oppose the application by Millstone's current owner, Dominion Nuclear Connecticut, Inc., to extend the reactor operating licenses by 20 years. An extension would allow Unit to operate through the year 2025 and Unit 3 until 2045.
"In the light of current knowledge of the unanticipated serious adverse effects on human health of extremely small doses of prolonged environmental radiation exposures . . . it is my professional opinion that the Millstone 2 and 3 reactors would need to end all radiation releases in order to meet public health requirements for safety," declared Dr. Ernest J. Sternglass, Professor Emeritus of Radiological Physics at the University of Pittsburgh School of Medicine.
"Therefore, they should not be granted license renewals to continue operations during the proposed twenty year renewal period without demonstrating that this objective can be achieved," Sternglass stated.
Sternglass cited a report published last April in the Journal of the American Medical Association which linked pregnant women's exposures to dental x-rays to premature births and low birth weights ñ even when the women were draped with lead shields.
Sternglass also cited recent studies that have found that baby teeth of children diagnosed with cancer have close to double the concentration of strontium-90 found in the teeth of otherwise healthy children born the same year and in the same area. Strontium-90 is a radioisotope emitted during the fission process from nuclear power plants.
Joseph J. Mangano, an epidemiologist with the Radiation and Public Health project, concurred with Dr. Sternglass' conclusions.
Mangano cited figures obtained from the Connecticut Tumor Registry, a division of the state Department of Health, which demonstrate that cancers affecting women are at their highest level in the New London area surrounding Millstone.

Mangano stated that any level of radiation is harmful at a cellular level and therefore the NRC should consider the current state of knowledge of the health effects from prolonged exposure to low levels of ionizing radiation, such as are emitted by Millstone, when it considers reactor relicensing.
"It is my professional opinion that the Millstone Nuclear Power operations present a continuing threat to the health of the community," Mangano stated. "As long as Millstone emits radioisotopes to the environment it will be a threat to the community."

Figures released by the NRC show that Millstone has emitted among the highest levels of radiation in gaseous and liquid form of any nuclear power station in the country.
Millstone has released 13,000 curies of tritium, a known cancer causing radioactive toxin which causes birth defects and genetic damage, directly into the air and water between 1991 and 2001, according to NRC reports.†
From 1971 to 2001, Millstone's total combined radioactive releases from Millstone Unit 1, 2 and 3 was 7,928,466 curies, according to the NRC.
. "We were promised that Millstone would create clean energy and be a boon to our community," Besade said. "Instead, Millstone has brought death and doom."
"This community should not accept any more unnecessary deaths and suffering because of Millstone," she said. "This community needs to wake up to the danger and close Millstone. Otherwise, the future will continue to bring illness, death and sorrow."
As a tribute to her father on the first anniversary of his passing, Besade released "Joe's Final Plea," a compilation of the messages her father wanted her to share with the community. "Joe's Final Plea" and Cynthia M. Besade's sworn statement to the NRC will appear on on August 16, 2004 on the Coalition's website at HYPERLINK "http://www.mothballmillstone.org" www.mothballmillstone.org .
The Connecticut Coalition Against Millstone is an organization of statewide safe energy and environmental groups, Millstone whistleblowers and individuals. The Coalition submitted the sworn statements of Besade, Dr. Sternglass, Mangano and others in support of its petition to intervene in the Millstone relicensing proceedings convened by the NRC.
Note to Editors: The sworn statements of Dr. Ernest J. Sternglass and Joseph J. Mangano and the April 28, 2004 report in the Journal of the American Medical Association ("Antepartum Dental Radiography and Infant Low Birth Rate") are available upon request.

Nuclear Fusion by Carole Bass - July 29, 2004

State Sen. Melodie Peters was elected to represent neighbors of the Millstone nuclear plant. Now shes also paid to represent Millstone itself. In May, state Sen. Melodie Peters had the "pleasure" of urging federal regulators to renew the Millstone nuclear power plant's operating license for another 20 years.
In July, Peters turned her pleasure to profit: Millstone's owner, Dominion Inc., hired her as a public relations consultant.
In essence, Dominion will pay Peters to do what she's been doing for free: helping to sell Millstone's license renewal to the public.
For the past 12 years, Democrat Peters has represented the chunk of southeastern Connecticut that includes Waterford and the Millstone reactors. As co-chair of the legislature's energy committee, she spearheaded Connecticut's 1998 electric industry restructuring law. That law forced Northeast Utilities to sell Millstone--opening the door for Virginia-based Dominion to buy it.
She credits Dominion with turning the place around. Especially its disastrous public safety record, lowlights of which included harassing whistleblowers and losing highly radioactive spent fuel rods.
Peters sees no conflict between her roles as elected representative of Millstone's neighbors and paid representative of Millstone to those neighbors.
"As a resident and as a senator, I have always been supportive of the relicensing," which would let the two Millstone reactors keep running until 2035 and 2045, Peters says.
"I firmly believe that we need nuclear energy to keep our lights on in this state. As long as it's a safely run entity, I'm in favor of it."
Tom Swan, the normally outspoken executive director of the watchdog Connecticut Citizen Action Group, is hesitant to criticize Peters' move. "We have always been close with Melodie," he says. But "it clearly raises flags."
P eters says Dominion approached her about doing PR work sometime "at the end of June, mid-June--I don't really remember." (A Dominion spokesman couldn't be reached for comment.) Peters started work at the beginning of July.
It's a short-term consulting contract, running through the end of the year "and then to be reconsidered," she says. That's roughly the same as Peters' remaining time in the Senate, since she's not seeking re-election this fall.
Her work will consist mainly of meeting with community groups about the license renewal. But she hasn't done much yet, because she's been busy caring for a terminally ill sister.
Peters won't say how much Dominion is paying her: "I don't believe I need to be discussing that with you."
Before taking the job, she checked with the state Ethics Commission. She didn't want to violate the revolving-door statute--which she co-wrote--prohibiting ex-legislators from lobbying for industries they used to regulate. The Ethics Commission told Peters she's fine as long as she doesn't represent Dominion in front of any state agencies for a year after leaving office.
That's the letter of the law. Peters also sees no conflict with the spirit of the ethics laws, which are supposed to make sure that politicians represent the best interests of their constituents above those of wealthy corporations.
Nor is she worried about the appearance of a conflict of interest.
"I'm so beyond appearances right now," she says. "If people don't know me and appreciate me for whom I am--especially after the 12 years I've represented the people of my district--then I've completely done something wrong. People trust me for being the honest, upfront person that I am."
A t the Nuclear Regulatory Commission's public hearing in Waterford on May 18, Peters was certainly upfront about where she stood.
"I just simply want to say it's my pleasure to stand here also endorsing" Millstone's license renewal, she told the regulators.
"It's critical not only for the energy needs of the state, it's critical for the relationship and the partnership that we've created together for this community and it's critical to sustaining southeastern Connecticut."
Besides cranking out roughly half of the state's electricity, she said, "there's a host of contributions that [Dominion has] made to improve the quality of life in our region."
Now Dominion is making a contribution to Peters' quality of life as well.
Use our contact form to write to Carole Bass. by Carole Bass - July 29, 2004

State Sen. Melodie Peters was elected to represent neighbors of the Millstone nuclear plant. Now shes also paid to represent Millstone itself. In May, state Sen. Melodie Peters had the "pleasure" of urging federal regulators to renew the Millstone nuclear power plant's operating license for another 20 years.
In July, Peters turned her pleasure to profit: Millstone's owner, Dominion Inc., hired her as a public relations consultant.
In essence, Dominion will pay Peters to do what she's been doing for free: helping to sell Millstone's license renewal to the public.
For the past 12 years, Democrat Peters has represented the chunk of southeastern Connecticut that includes Waterford and the Millstone reactors. As co-chair of the legislature's energy committee, she spearheaded Connecticut's 1998 electric industry restructuring law. That law forced Northeast Utilities to sell Millstone--opening the door for Virginia-based Dominion to buy it.
She credits Dominion with turning the place around. Especially its disastrous public safety record, lowlights of which included harassing whistleblowers and losing highly radioactive spent fuel rods.
Peters sees no conflict between her roles as elected representative of Millstone's neighbors and paid representative of Millstone to those neighbors.
"As a resident and as a senator, I have always been supportive of the relicensing," which would let the two Millstone reactors keep running until 2035 and 2045, Peters says.
"I firmly believe that we need nuclear energy to keep our lights on in this state. As long as it's a safely run entity, I'm in favor of it."
Tom Swan, the normally outspoken executive director of the watchdog Connecticut Citizen Action Group, is hesitant to criticize Peters' move. "We have always been close with Melodie," he says. But "it clearly raises flags."
P eters says Dominion approached her about doing PR work sometime "at the end of June, mid-June--I don't really remember." (A Dominion spokesman couldn't be reached for comment.) Peters started work at the beginning of July.
It's a short-term consulting contract, running through the end of the year "and then to be reconsidered," she says. That's roughly the same as Peters' remaining time in the Senate, since she's not seeking re-election this fall.
Her work will consist mainly of meeting with community groups about the license renewal. But she hasn't done much yet, because she's been busy caring for a terminally ill sister.
Peters won't say how much Dominion is paying her: "I don't believe I need to be discussing that with you."
Before taking the job, she checked with the state Ethics Commission. She didn't want to violate the revolving-door statute--which she co-wrote--prohibiting ex-legislators from lobbying for industries they used to regulate. The Ethics Commission told Peters she's fine as long as she doesn't represent Dominion in front of any state agencies for a year after leaving office.
That's the letter of the law. Peters also sees no conflict with the spirit of the ethics laws, which are supposed to make sure that politicians represent the best interests of their constituents above those of wealthy corporations.
Nor is she worried about the appearance of a conflict of interest.
"I'm so beyond appearances right now," she says. "If people don't know me and appreciate me for whom I am--especially after the 12 years I've represented the people of my district--then I've completely done something wrong. People trust me for being the honest, upfront person that I am."
A t the Nuclear Regulatory Commission's public hearing in Waterford on May 18, Peters was certainly upfront about where she stood.
"I just simply want to say it's my pleasure to stand here also endorsing" Millstone's license renewal, she told the regulators.
"It's critical not only for the energy needs of the state, it's critical for the relationship and the partnership that we've created together for this community and it's critical to sustaining southeastern Connecticut."
Besides cranking out roughly half of the state's electricity, she said, "there's a host of contributions that [Dominion has] made to improve the quality of life in our region."
Now Dominion is making a contribution to Peters' quality of life as well.
Use our contact form to write to Carole Bass.

UN CHILDREN'S CONFERENCE ON ENVIRONMENT- New Haven Advocate
Hundreds of kids from around the world are gathered in New London this week for a hands-on environmental conference. They're sailing Long Island Sound and the Thames River, finding out what critters live in those waters. They're visiting the Mashantucket Pequot Museum, learning about traditional healing and native people's respect for Mother Earth. They're hearing keynote speaker Jane Goodall explain how individuals can make a difference.
And on Friday, 30 kids will learn about the environmental impact of nuclear power--on a field trip to the Millstone plant.
Will they hear about how Millstone sucks billions of gallons of Sound water into its cooling system every day--pulverizing fish and fish eggs along the way--and then spits the water back out at temperatures high enough to kill underwater plants and animals? Will they hear about the toxic chemicals and heavy metals that pour out along with the warm water? Will they hear about the radiation Millstone puts in the air, and the elevated cancer rates in surrounding towns? Will they hear about Millstone's radioactive waste, stored in Waterford, which will remain deadly for thousands of years?
Not likely.
Young delegates to the 2004 Tunza International Children's Conference on the Environment can probably expect to hear a pitch for nukes as a clean, environmentally sound source of the electricity that is essential to our quality of life, both here and in the developing world.
The 10-to-13-year-old environmentalists, brought together by the United Nations Environmental Program, probably also won't hear that Millstone owner Dominion Resources put up $10,000 as a conference sponsor.
We say "probably" because Millstone spokesmen didn't respond to phone messages about the field trip. And conference organizers, who did return phone calls and defended the field trip, are vague about what kids will hear at Millstone. They're also vague about whether anyone else will tell kids about the downside of nuclear power.
Anti-Millstone activist Nancy Burton wants to be that anyone.
Burton called conference organizers this month, asking if her group, Connecticut Coalition Against Millstone, could become a sponsor. A staffer told Burton that Dominion was already signed on, so CCAM's presence would not be a "good fit."
That's also when Burton learned about the field trip to Millstone. She fired off a letter to conference director Barbara Morgan.
Noting that the conference's title, "Tunza," comes from a Kiswahili word meaning "to treat with care or affection," Burton wrote: "Dominion does not treat the environment with either 'care' or 'affection' at Millstone." She called for ditching the Millstone field trip and allowing her group to become a sponsor and information presenter.
At least one conference participant--Clearwater, the Hudson River sloop & cleanup organization made famous by folksinger Pete Seeger--is dismayed to hear of the Millstone connection.
"We think it's unfortunate that the event has allowed the money from Millstone to be used as part of their sponsorship," says Manna Jo Greene, Clearwater's environmental director. "We would never take money from a nuclear power facility."
And, she says, it's "extremely unfortunate that children are going to be used, and oriented to believe that this is a clean form of energy. I will alert our educators to counteract that misinformation" as they teach kids about the ecology of Long Island Sound.
A quarter-century ago, the No Nukes movement had money, celebrities and wimpy pop songs at its disposal. Nowadays, kids likely know little about nuclear power beyond Homer Simpson and Blinky the three-eyed fish.
But with the Bush administration pushing for construction of the country's first new nuclear reactors in decades, it's not surprising that Dominion--a Virginia-based energy giant that owns nuclear, hydroelectric and coal-burning power plants--should see the International Children's Conference on the Environment as a chance for some good publicity.
The conference is a big deal. An outgrowth of the 1992 Rio Earth Summit, it aims to involve kids in environmentally friendly practices and policies. This week's conference, hosted by Connecticut College, is the fourth ever, and the first in the United States.
Its "founding sponsor," the Mashantucket Pequot Tribal Nation, has provided more than $1 million in cash and in-kind services toward the conference's $3.2 million budget, Morgan says. The rest comes from private donors and corporate sponsors--like Dominion.
Morgan says Dominion's $10,000 sponsorship and the Millstone field trip are "independent" of each other.
But, she acknowledges, "we talked to [Dominion] about both at the same time, of course." And she says the two organizations agreed on the field trip before Dominion committed to the sponsorship.
So how does a trip to a nuclear power plant--with information coming solely from the people who run the plant--fit into the scope of an environmental conference? Morgan is hard-pressed to explain.
Poking around the conference's Web site, HYPERLINK "http://www.icc04.org/" www.icc04.org >, turns up mention of numerous other field trips and workshops. They're all conducted by non-profit educational and environmental organizations: The Pequot and Peabody museums. Clearwater, Schooner Inc. and Soundwaters, all of which teach marine ecology aboard tall sailing ships. Mystic Aquarium. Dominion appears to be the only for-profit company and the only commercial/industrial outfit involved in "educating" the 450 young delegates from 45 countries.
"Nuclear power is a reality in many, many parts of the world," including Connecticut, Morgan points out. "We're educating children about environmental issues. Nuclear power is an educational issue, no matter which side you come down on."
The field trip is part of a day with the theme, "Energy: Renew It, Reuse It, Recycle It." The day's other activities include building a battery from a potato and two coins, and a workshop about earthworms and composting.
A sked whether she considers nuclear power a renewable energy source, Morgan replies: "Gee, you're talking to the chief accountant-slash-fundraiser-slash-organizer. You're not talking to anybody who has any science background. I don't know enough about nuclear power to say whether I would personally consider it a renewable energy. It doesn't seem so."
She refers further questions on that subject to program coordinator Laurel Kohl. Kohl is a trained scientist who works at Eastern Connecticut State University's Institute for Sustainable Energy.
Does Kohl consider nuclear power a renewable energy source?
"I don't think my opinion is relevant to this conversation," she responds. "My job as an educator is to present information so that our future leaders can make informed decisions."
Here's a quote from her Institute's "What is Energy?" Web page: "Nuclear energy is a nonsustainable form of energy."
Like Morgan, Kohl emphasizes that nuclear power "is a reality," whether we like it or not. She says the field trip will focus on Millstone scientists who monitor the air and water around the plant, to make sure it complies with environmental regulations.
"It's a way to show scientists at work," she says--"that science is important, that there are real jobs out there."
Millstone's Web site boasts that, "unlike many other fuels used in power plants to produce electricity, nuclear energy has a low impact on the environment, including the air, land, water and wildlife."
Is that what the conference kids will hear at Millstone? Kohl says she doesn't know.
Will they hear anything critical of Millstone or nuclear power?
"You couldn't realistically say, 'Here is our group of scientists'" monitoring environmental impact and imply there is no problem, Kohl says. "Why would you need them if there's no problem?"
You also couldn't realistically expect Millstone employees to dispute the company line that nuclear power is clean & green. Will anyone else at the conference tackle the subject from a more critical stance?
"I think many of our students are very informed citizens," Kohl says. "It's a special group of students."
But will the conference itself help them become informed about the dangers of nuclear plants?
"Do you truly believe," Kohl asks, "that every statement must be balanced, if you will, by its opposite? Because I've got a composting workshop, does that mean I've got to have the pro-garbage, throw-it-away point of view represented?"
A t press time, Burton and conference director Barbara Morgan were negotiating over whether the Connecticut Coalition Against Millstone could distribute anti-nuclear information at the conference.
Or they could ask some of the conference's other teachers.
Jane Goodall, for instance. The keynote speaker, honorary chairwoman and world-famous ape researcher, had this to say about nuclear power in November 2000:
"As a person deeply concerned about wildlife, the natural environment, and children's education, it is impossible for me not to be afraid of nuclear energy. In fact, after the Chernobyl and Three Mile Island nuclear power plant incidents, we have learned our lessons. The U.S. no longer constructs nuclear power plants."
Or the conference organizers could review their own newsletter of a year ago, in which an early outline said that Day 4 would "take the delegates on a journey through the world of renewable energy, recycling, and waste reduction."
Evidently there's been a reduction in those admirable goals. What a waste.

CONNECTICUT COALITION AGAINST MILLSTONE
P.O. Box 415 Niantic CT 06357
July 15, 2004
Klaus Toepfer
Executive Director
United Nations Environment Programme
P.O. Box 30552
Nairobi, Kenya
Re: "United Nations Children's Conference on the Environment"
Dear Mr. Toepfer:
We write to request your urgent intervention to stop the commercial sponsors of the United Nations Children's Conference on the Environment from taking the 10-to-13-year-old participants from nations around the world on a "field trip" to the Millstone Nuclear Power Plant next week.
We contacted you yesterday to protest the exclusion of the Connecticut Coalition Against Millstone as a sponsor of this important conference - and to protest the inclusion of Dominion (owner and operator of the Millstone nuclear facility) - as a $10,000 sponsor.
Today we write to inform you of today's news reports that the Millstone nuclear site which the children are scheduled to visit has been identified as containing 19 areas of radiological and toxic chemical contamination.
To our knowledge, the report of the widespread contamination has not been made public and is being withheld by Dominion.
I attach for your information a copy of the news article which appears in today's New London Day entitled "Chemicals in Ground at Millstone."
You should be aware that any level of ionizing radiation is dangerous to health because of its potential to disrupt cellular functions. Children are most vulnerable to these effects.
Since this information about radiological and toxic contamination at the Millstone site has just become public today, we are concerned that the children and their families attending the United Nations conference in New London and the field trip to Millstone were not fully informed by the sponsor, Dominion, of the risks and hazards to their health from participating in the field trip.
We request that you and your office investigate these circumstances immediately and take what steps are necessary to protect the children from unwanted and unnecessary exposure to radiological and toxic contamination as participants in the Children's Conference on the Environment.Sincerely,Nancy Burton, Esq.
Encl.
cc: Hon. Kofi Annan, Secretary-General of the United Nations
Hon. Sen. Joe Lieberman
Hon. Sen. Christopher Dodd
Hon. Rep. Rob Simmons
Hon. Gov. Jodi Rell
Hon. Richard S. Blumenthal

Chemicals In Ground At Millstone
Study finds 19 areas; metal and oil alloys pose no health hazard

By PATRICIA DADDONA
Day Staff Writer, Waterford
Published on 7/15/2004

Waterford - The owner of Millstone Power Station has found 19 areas in the ground contaminated with oil or metal alloys after a study ordered by the state when the company bought the property in 2001.
Dominion Nuclear Connecticut, which operates the nuclear power complex, also found trace levels of radioactivity in soils and on building surfaces. Officials from the state Department of Environmental Protection said they pose no health threat.
When Dominion purchased the power station three years ago, the company agreed to investigate where chemical spills might exist and clean up problem areas, said Peter Hill of the DEP. The self-assessment and the removal of contaminated soils are required under the state's Property Transfer Act, Hill said. Dominion hired Groundwater Environmental Services of Windsor to evaluate contamination and complete cleanup, according to Hill.
Dominion refused to allow Gary Iadarola, a licensed environmental professional with GES, to comment on his fieldwork.
Cleanup will begin in August, Hyde said.
Located on a peninsula that juts into Long Island Sound, Millstone is the site of two operating power plants and one that is being decommissioned.
According to Hill, Dominion initially identified 59 or fewer potential "areas of concern." On Tuesday, spokesman Pete Hyde put the number at 69, which Hill said was an indication that the company's investigation is thorough.
Of the 19 spots at Millstone where cleanup is needed, most are composed of soils where oil or metal alloys were left in the ground after oil or water tanks were removed, Hyde said.
Soil beneath a former salt shed once used to store scrap metal, for instance, will have to be taken to a hazardous waste landfill that accepts such material, Hyde said. The shed is located off the site's main access road on land surrounded on three sides by woods.
The state will not evaluate Dominion's assessment until the cleanup is done, Hill said. After that, the company must continuously monitor groundwater.
"We're not doing this because we found something," Hyde said. "This has been on the table since we bought the place. There's no threat to worker safety or worker health."
Since DEP doesn't impose a deadline, Dominion will "take as long as is needed" to address each contaminated area and any new ones DEP may find when it inspects the station after cleanup is complete, Hyde said.
"For each of the 19, we're going to develop a plan, define the area, dig out the problem and fix it, so it's going to take as long as it takes," he said. "The point is to get it cleaned up thoroughly."
Hill and Michael Firsick, a supervising radiation control physicist with DEP's air monitoring bureau, confirmed that the amount of radioactivity Dominion detected poses no health threat on- or off-site.
In lab and computer analysis, DEP determined that trace amounts were present in soil samples, he said.
The entire site generates about 25 millirems of radioactivity a year - less than the amount produced in a typical chest X-ray, Hyde said. Firsick characterized background radioactivity, the amount to which most people are routinely exposed, as 360 millirems a year.
p.daddona@theday.com

© The Day Publishing Co., 2004
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CONNECTICUT COALITION AGAINST MILLSTONE
P.O. Box 415 Niantic CT 06357

ANTI-MILLSTONE GROUP PROTESTS ITS EXCLUSION, MILLSTONE'S INCLUSION, AT UN CHILDREN'S CONFERENCE ON ENVIRONMENT;
CHARGES PROGRAM EXPLOITS CHILDREN TO PROMOTE NUCLEAR POWER
For Immediate Release July 14, 2004
Contact: Nancy Burton 203-938-3952/203-545-9252
Mitzi Bowman 203-389-2067
The Connecticut Coalition Against Millstone protested today to the Director of the United Nations Environmental Program that a UN-sponsored program is being used to exploit children to promote nuclear power.
The Coalition called upon Klaus Toepfer, head of the UN Environment Programme based in Nairobi, Kenya, to intervene on behalf of the 400 children from around the world scheduled to participate in five-day a conference on the environment in New London beginning July 19.
"Exploitation of children to promote dangerous nuclear technology is a subversion of the goals and mission of the UN Environment Programme," wrote Nancy Burton, the Coalition's attorney, in a message to Toepfer.
The Coalition protested that the sponsor of the event, the International Children's Conference on the Environment, had rejected the Coalition's offer of sponsorship while accepting a $10,000 sponsorship by Dominion, the company that owns and operates the Millstone Nuclear Plant in Waterford, Connecticut.
"We were told by your office that Connecticut Coalition Against Millstone sponsorship would not be a "good fit" with Dominion sponsorship," the Coalition wrote to ICCE.
"We question whether Dominion sponsorship is a "good fit" with the United Nations Children's Conference on the Environment," the letter said.
The Coalition said Dominion's operations of the nuclear facility are contrary to the spirit of the conference, which is titled "Tunza," from the Kiswahili word meaning "to treat with care or affection."
"Dominion does not treat the environment with either 'care' or 'affection' at Millstone," the Coalition charged, noting the facility's releases of radioactive byproducts and toxic chemicals to the air and water.
The Coalition protested the conference plans to send the 400 10-to-13-year-olds on a field trip to the nuclear site.
"We believe that such a trip will put at risk their health and safety," the Coalition stated. "Just being near Millstone raises the risk of harmful physical effects. A citizen's group monitoring Millstone's emissions near the site with radiation detectors has counted elevated levels of ionizing radiation, higher than background radiation levels away from the site."
"An official United Nations program - ostensibly offered to promote respect for the environment - should not be subverted to exploit children, subject them to health risks and bombard them with propaganda to sell a product: nuclear power, the greatest worldwide threat to the environmental health of the planet," the Coalition stated.
Information on the conference is available at www.icc04.org.
- 30 -
Editor's Note: A copy of the Coalition letter to ICCE is attached.
CONNECTICUT COALITION AGAINST MILLSTONE
P.O. Box 415 Niantic CT 06357
July 14, 2004
Barbara Morgan
International Children's Conference on the Environment
305 State Street
New London CT 06320
Dear Ms. Morgan:
We applaud the initiative of the Mashantucket Pequot Tribal Nation in supporting the United Nations Children's Conference on the Environment to be held in New London July 19-23.
The conference will provide an excellent opportunity for the 400 enrolling children aged 10-13 from around the world to learn about environmental conservation and sustainable development. The title chosen for the conference, "Tunza," from the Kiswahili word meaning "to treat with care or affection," is apt.
When we recently learned that you were seeking additional sponsors for the event, we offered to become a sponsor.
We were distressed to be told by ICCE on July 9 that it would reject the Coalition's offer of sponsorship because Dominion, the company that owns and operates Millstone, has become a major sponsor and is participating in the conference.

We were told by your office that Connecticut Coalition Against Millstone sponsorship would not be a "good fit" with Dominion sponsorship.
We question whether Dominion sponsorship is a "good fit" with the United Nations Children's Conference on the Environment.
Dominion does not treat the environment with either "care" or "affection" at Millstone.
Millstone routinely releases harmful radiation into the air and water. Millstone's nuclear reactors in Waterford released 23,000 curies of tritium, a known cancer-causing radioactive toxin causing birth defects and genetic damage, directly into the air and water between 1991 and 2002. From 1971 to 2001, Millstone's total combined radioactive releases amounted to 7,928,466 curies. Many radioactive gases decay into solid radioactive particles after they are released.
Millstone routinely releases toxic chemicals into the Long Island Sound, including hydrazine, which is known to cause cancer in fish. In 1998, Millstone's owner pleaded guilty in the U.S. District Court to committing environmental felonies in violation of the federal Clean Water Act. It paid a $10 million fine.
We hold Millstone accountable for the collapse of the indigenous fish stocks which have been destroyed at the giant Millstone intake structures.
We hope that you will reconsider your rejection of the Coalition's offer of sponsorship.
At the same time, we urge you to forego your plans to take the 400 young participants on a field trip to the Millstone nuclear site. We believe that such a trip will put at risk their health and safety. Just being near Millstone raises the risk of harmful physical effects. A citizen's group monitoring Millstone's emissions near the site with radiation detectors has counted elevated levels of ionizing radiation, higher than background radiation levels away from the site.
A Waterford High School sophomore was diagnosed within the past year with ovarian cancer. Earlier this month, a college student, who lived across Niantic Bay from Millstone when she was 10 years old, was operated on for the third time with a rare cancer her doctor said is not uncommon in Chernobyl victims. Cancer clusters have been identified in the costal areas surrounding Millstone.
An official United Nations program - ostensibly offered to promote respect for the environment - should not be subverted to exploit children, subject them to health risks and bombard them with propaganda to sell a product: nuclear power, the greatest worldwide threat to the environmental health of the planet.
We look forward to your response.Sincerely,Nancy Burton, Esq.

CONNECTICUT COALITION AGAINST MILLSTONE
P.O. Box 415 Niantic CT 06357
July 14, 2004

Barbara Morgan
International Children's Conference on the Environment
305 State Street
New London CT 06320

Dear Ms. Morgan:
We applaud the initiative of the Mashantucket Pequot Tribal Nation in supporting the United Nations Children's Conference on the Environment to be held in New London July 19-23.
The conference will provide an excellent opportunity for the 400 enrolling children aged 10-13 from around the world to learn about environmental conservation and sustainable development. The title chosen for the conference, "Tunza," from the Kiswahili word meaning "to treat with care or affection," is apt.
When we recently learned that you were seeking additional sponsors for the event, we offered to become a sponsor.
We were distressed to be told by ICCE on July 9 that it would reject the Coalition's offer of sponsorship because Dominion, the company that owns and operates Millstone, has become a major sponsor and is participating in the conference.

We were told by your office that Connecticut Coalition Against Millstone sponsorship would not be a "good fit" with Dominion sponsorship.
We question whether Dominion sponsorship is a "good fit" with the United Nations Children's Conference on the Environment.
Dominion does not treat the environment with either "care" or "affection" at Millstone.
Millstone routinely releases harmful radiation into the air and water. Millstone's nuclear reactors in Waterford released 23,000 curies of tritium, a known cancer-causing radioactive toxin causing birth defects and genetic damage, directly into the air and water between 1991 and 2002. From 1971 to 2001, Millstone's total combined radioactive releases amounted to 7,928,466 curies. Many radioactive gases decay into solid radioactive particles after they are released.
Millstone routinely releases toxic chemicals into the Long Island Sound, including hydrazine, which is known to cause cancer in fish. In 1998, Millstone's owner pleaded guilty in the U.S. District Court to committing environmental felonies in violation of the federal Clean Water Act. It paid a $10 million fine.
We hold Millstone accountable for the collapse of the indigenous fish stocks which have been destroyed at the giant Millstone intake structures.
We hope that you will reconsider your rejection of the Coalition's offer of sponsorship.
At the same time, we urge you to forego your plans to take the 400 young participants on a field trip to the Millstone nuclear site. We believe that such a trip will put at risk their health and safety. Just being near Millstone raises the risk of harmful physical effects. A citizen's group monitoring Millstone's emissions near the site with radiation detectors has counted elevated levels of ionizing radiation, higher than background radiation levels away from the site.
A Waterford High School sophomore was diagnosed within the past year with ovarian cancer. Earlier this month, a college student, who lived across Niantic Bay from Millstone when she was 10 years old, was operated on for the third time with a rare cancer her doctor said is not uncommon in Cherno