Full opinion text
MEMORANDUM RAMBO, Chief Judge. On March 28, 1979, a nuclear incident occurred at the Unit 2 reactor of the Three Mile Island nuclear power facility in Dauphin County, Pennsylvania. Among other things, the incident spawned the instant litigation which has been pending on the court’s docket for one decade longer than all but one case on the court’s docket. Due in significant part to the tremendous amount of time and effort expended by the parties and the court over the past year, ten test cases were finally scheduled for trial beginning in June. In January and April of this year, the court issued a series of Daubert rulings excluding the bulk of Plaintiffs’ expert scientific testimony as scientifically unreliable. In re TMI Cases Consol. II, 166 F.R.D. 8 (M.D.Pa.1996) (granting in part Defendants’ motions in limine to exclude Plaintiffs’ medical causation experts); id. 922 F.Supp. 1038 (M.D.Pa.1996) (same); id. 922 F.Supp. 997 (M.D.Pa.1996) (granting in part Defendants’ motions in limine to exclude Plaintiffs’ dose and medical causation experts); id. 910 F.Supp. 200 (M.D.Pa.1996) (granting in part Defendants’ motion in limine to exclude Plaintiffs’ dose experts); id. 911 F.Supp. 775 (M.D.Pa.1996) (same). Defendants now move for summary judgment. The parties have briefed the issues and Defendants’ motion is ripe for disposition. Before reaching the merits of Defendants’ motion, however, the court must first address the subsidiary yet important issue of to whom the court’s summary judgment ruling will apply. Defendants argue that based upon the way in which they have framed their motion, any ruling by the court should be binding upon all Plaintiffs. Conversely, Plaintiffs argue that the ruling should bind only the test Plaintiffs. To resolve this issue, the court refers back to its memorandum and accompanying order dated June 15,1993. Through that order the court adopted Plaintiffs’ proposed case management plan and “test plaintiff’ approach, and rejected Defendants’ case management plan and “track litigation” approach. In its discussion of Plaintiffs’ proposed plan, the court noted the following: Plaintiffs claim that this initial trial would provide a basis for the parties realistically to evaluate their respective eases and promote settlement of this action. Defendants contend that “the ‘test-ease’ approach does not portend to resolve anything except the test cases selected.” Therefore, Defendants assert that the initial twelve-Plaintiff trial would not promote settlement or be otherwise useful. In re TMI Cases Consolidated II, No. 1:CV-88-1452, mem. op. at 26 (M.D.Pa. June 15, 1993) (footnote added). Defendants now argue that “[t]he fact that the court has scheduled trial for ten ‘test case’ plaintiffs does not mean that all the pretrial consolidated proceedings, designated with the caption ‘All Plaintiffs,’ should ... be regarded retrospectively as applicable only to those ‘test case’ plaintiffs.” (Defs.’ Reply Mem. at 26.) Indeed, the purpose of consolidating an action pursuant to Federal Rule of Civil Procedure 42(a) is to streamline and economize pretrial proceedings so as to avoid duplication of effort, and to prevent conflicting outcomes in cases involving similar legal and factual issues. See In re Prudential Securities Incorporated Ltd. Partnerships Litigation, 158 F.R.D. 562, 571 (S.D.N.Y.1994); Bank of Montreal v. Eagle Associates, 117 F.R.D. 530, 533 (S.D.N.Y.1987). The court finds that resolution of the issue before it turns on the grounds upon which the court ultimately grants or denies summary judgment. Defendants are correct that to the extent the ruling turns on broad evidentiary issues common to all Plaintiffs, the ruling will be binding upon all Plaintiffs. Likewise, Plaintiffs are correct that insofar as a ruling is based upon a more narrow, Plaintiff-specific inquiry, the ruling will apply only to certain Plaintiffs. The court’s reading of documents related to the June 15,1993 order, in conjunction with subsequent case management orders and evidentiary rulings, indicates that discovery and evidentiary matters were to proceed on an “All Plaintiffs” basis. A contrary intention or result would obviate all benefits of having consolidated the many separate actions. Each Plaintiffs case depends upon expert testimony to prove both exposure and medical causation. Expert discovery is complete, and all expert reports have been filed. Thus, to the extent that the expert testimony of record fails to meet the test Plaintiffs’ evidentiary burden at this stage of the litigation, it will fail to meet the same burden as to every Plaintiff. It would be an exercise in futility and a waste of valuable resources to allow the many separate actions consolidated under this caption to proceed if it were clear that the cases could not withstand a motion for summary judgment. Under such circumstances, the court’s summary judgment ruling would be applicable to all Plaintiffs. In accordance with the discussion that follows, the court will grant Defendants’ motion for summary judgment on the ground that Plaintiffs have failed to present evidence sufficient to create a material factual dispute on the issue of dose, and therefore, have failed to state their prima facie case. Because the court finds the quantum of Plaintiffs’ expert evidence on the issue of dose to be insufficient, and because no Plaintiff will be able to state a prima facie ease without adequate dose evidence, the instant ruling is binding upon all Plaintiffs. I. Background A. Procedural History The consolidated claims in this case were initially filed shortly after the TMI incident in the state and federal courts of Pennsylvania, New Jersey and Mississippi. Since the initial filings, these cases have traveled to and from the Supreme Court, the Third Circuit Court of Appeals, and several district courts on numerous occasions. Moreover, jurisdictional questions related to these actions prompted Congress to amend the Price Anderson Act to ensure federal court jurisdiction, see S.Rep. 100-218, 100th Cong.2d Sess., 1988 U.S.C.C.A.N. 1424, 1476, 1488 (noting that the TMI litigation provided the impetus for amending the federal jurisdiction section of the Act). A brief review of the consolidated claims’ meandering journey to this court is warranted. In the mid and late 1980s, based upon the assertion that Plaintiffs’ claims arose under the Price Anderson Act, Pub.L. No. 85-256, 71 Stat. 576 (codified as amended in various sections of title 42 of the United States Code), Defendants removed Plaintiffs’ state court actions to federal courts in Pennsylvania and Mississippi. On appeal, the Third Circuit found that because the Nuclear Regulatory Commission (“NRC”) had determined that the TMI incident did not constitute an “extraordinary nuclear occurrence,” the TMI claims did not arise under the provisions of the Price-Anderson Act. Stibitz v. General Pub. Utils. Corp., 746 F.2d 993 (3d Cir.1984), cert. denied, 469 U.S. 1214, 105 S.Ct. 1187, 84 L.Ed.2d 334 (1985); Kiick v. Metropolitan Edison Co., 784 F.2d 490 (3d Cir.1986). As such, the Third Circuit ruled that this court lacked jurisdiction to hear the actions. Stibitz, 746 F.2d at 997; Kiick, 784 F.2d at 494-95. Pursuant to that rulings, this court remanded those actions originally filed in state court, and transferred those actions originally filed in federal court, to the appropriate state courts. Following this court’s remand and transfer of cases to state courts, Congress amended the Price-Anderson Act. 42 U.S.C. § 2011 (Price-Anderson Amendments Act of 1988). The amendment retroactively provided a federal forum for all claims arising out of any nuclear incident, whether or not that incident was declared to be an “extraordinary nuclear occurrence.” 42 U.S.C. § 2210(n)(2). Original jurisdiction was conferred upon district courts located where the incident occurred, and provision was made for the removal of any action previously filed or currently pending in state court. § 2210(n)(2). Subsequently, the constitutionality of the Act’s federal forum provision was upheld in In re TMI Litigation Cases Consol. II, 940 F.2d 832 (3d Cir.1991), cert. denied, 503 U.S. 906, 112 S.Ct. 1262, 117 L.Ed.2d 491 (1992). Pursuant to § 2210(n)(2), all remaining claims were then consolidated in this court. On January 26, 1993, Defendants moved for summary judgment on all pending personal injury claims on the element of duty of care. Defendants argued that to prove liability, Plaintiffs would need to demonstrate that Defendants violated their duty of care by exposing each Plaintiff to radiation in excess of .5 rem. See infra at 840-841 (defining “rem”). On February 18, 1994, this court issued a memorandum and order denying Defendants’ motion. The Third Circuit affirmed this court’s ruling in part, holding that “the duty of care is measured by whether defendants released radiation in excess of the levels permitted by [10 C.F.R.] §§ 20.105 or 20.106, as measured at the boundary of the facility, not whether each plaintiff was exposed to those excessive radiation levels.” In re TMI Litig. Cases Consol. II, 67 F.3d 1103, 1117-18 (3d Cir.1995), cert. denied, — U.S. -, 116 S.Ct. 1034, 134 L.Ed.2d 111 (1996). In November of 1995, and in February and March of 1996, this court conducted extensive Daubert hearings related to Plaintiffs’ dose and medical causation experts. In January and April of 1996, this court issued several memoranda of law and accompanying orders granting the majority of Defendants’ motions in limine. As these opinions, hundreds of pages in aggregate length, detail the court’s reasoning, the court will not restate that reasoning here. In brief, however, the court notes that despite finding the vast majority of Plaintiffs’ experts to be well qualified, the court found many of their opinions to be based upon methodologies that were scientifically unreliable and upon data that a reasonable expert in the field would not rely upon. Accordingly, in the exercise of its “gatekeeping” function, the court found it necessary to exclude much of Plaintiffs’ proffered expert testimony. On April 19, 1996, Defendants filed the instant motion for summary judgment on the issues of dose and medical causation. B. Scientific Background To understand the framework through which the court must view the scientific evidence in this case, it is necessary to have a basic understanding of the concepts and principles used by scientists to evaluate the impact of radiation exposure in human beings. The court will first provide a brief overview of basic concepts of radiation. Next the court will review relevant dose-related terms and concepts including the concept of background radiation, and the processes of dose reconstruction and risk assessment. Finally, the court will explain the basic operation of a Babcox & Wilcox pressurized water nuclear reactor, and will discuss general meteorological concepts relevant to the movement and dispersion of radioactive plumes. 1. Basic Concepts of Radiation Atoms are the smallest unit of an element, and are composed of three types of particles: protons, neutrons and electrons. They may be stable or unstable. Unstable atoms emit surplus energy from the nucleus in a process known as radioactive decay. The energy emitted through radioactive decay is radiation. See generally, Allen v. United States, 588 F.Supp. 247, 260-87 (D.Utah 1984) (providing exhaustive discussion of basic principles of radiation and nuclear physics). For the purposes of this lawsuit, there are three basic types of ionizing radiation. An alpha particle is composed of two neutrons and two protons---- A beta ray is a single electron. A gamma ray is a photon, or bundle of energy which contains some of the properties of both matter and light. Johnston v. United States, 597 F.Supp. 374, 384 (D.Kan.1984) (emphasis added). Gamma radiation is short wave length electromagnetic radiation spontaneously emitted by a nucleus during certain radioactive decays. (7/12/95 Aff. of John Fraizer at ¶ 14.) It has a high penetrating ability and can pass through the human body. In the instant action, Plaintiffs allege gamma ray exposure from xenon, radioactive iodine, and to a lesser extent, krypton. Scientists quantify radiation in the following manner: [a]s radiation passes through air, it can be measured by counting the number of ionized particles it produces. The quantity ‘exposure’ has been historically defined as the number of electrical charges produced in a unit mass of air and measured in units of roentgens (R)____ As radiation penetrates any material, its energy is absorbed and released by the constituent atoms. The absorbed energy per unit mass of material is termed the absorbed dose. The old unit of absorbed dose was the rad, defined as 100 ergs of energy per gram of material____ The effects of radiation on any material, including biological materials such as tissue, depend on the magnitude of the absorbed dose. International Advisory Committee, “The International Chernobyl Project, Technical Report,” at 20 (IAEA 1991) (hereinafter “Chernobyl Report”). The rad has been replaced by the international unit, the “gray” (Gy). One gray is equal to 100 rads. Another relevant dosimetric quantity is the “rem” (roentgen equivalent man). One rem is equal to one thousand milirems (mrems). The rem has been replaced by the international unit the “sievert” (Sv). One sievert equals 100 rems (100,000 mrems). Because much of the TMI literature predates the conversion to international units, the court will use rad and rem quantities to insure consistency with materials being cited. 2. Radiation Exposure and Dose a. Background Radiation All persons are exposed to radiation in their day to day existence. This radiation, known as “background radiation,” comes from both natural and man-made sources. National Research Council, Committee on the Biological Effects of Ionizing Radiation, “Health Effects of Exposure to Low Levels of Ionizing Radiation” at 17 (1990) (“BIER V”); see also Chernobyl Report at 23-28. The BEIR Y report states the following regarding annual exposure to background radiation in the United States: three of the six radiation sources, namely radiation from occupational activities, nuclear power production (the fuel cycle), and miscellaneous environmental sources (including nuclear weapons testing fallout), contributed negligibly to the average effective dose equivalent, i.e., less than 0.01 millisievert (mSv)/year (1 mrem/year). A total average annual effective dose equivalent of 3.6 mSv (360 mrem)/year to members of the U.S. population is contributed by the other three sources: naturally occurring radiation, medical uses of radiation, and radiation from consumer products. By far the largest contribution (82%) is made by natural sources, two thirds of which is caused by radon and its decay products. Approximately equal contributions to the other one-third come from cosmic radiation, terrestrial radiation, and internally deposited radionuclides. The importance of environmental radon as the largest source of human exposure has only recently been recognized. The remaining 18% of the average annual effective dose equivalent consists of radiation from medical procedures (x-ray diagnosis, 11% and nuclear medicine, 4%) and from consumer products (3%). The contribution by medical procedures is smaller than previously estimated. For consumer products, the chief contributor is, again, radon in domestic water supplies, although building materials, mining, and agricultural products as well as coal burning also contribute. Smokers are additionally exposed to the natural radionuclide polonium-210 in tobacco, resulting in the irradiation of a small region of the bronchial epithelium to a relatively high dose ... that may cause an increased risk of lung cancer. BIER V at 18-19. The Johnston court also made the following interesting observations regarding natural background radiation: In order to make these units of measurement more meaningful, it is of interest to note what doses some common experiences yield. The earth in Florida gives a person living there a dose of approximately 23 mrem per year. If a person lives there for 64 years, he will receive a dose of 64 x 23 mrem = 1472 mrem from Florida dirt in a lifetime. This is equal to 1.472 rem. If another person lives in Colorado for 64 years, he will receive a dose of 64 x 90 mrem = 5760 mrem from Colorado dirt in a lifetime. This is equal to 5.76 rem. In 1970, approximately 129,000,000 Americans were exposed to x-rays for medical or dental purposes---- The average American by age 64 will receive about 6.5 rem of radiation from x-rays. Consequently, total [ (lifetime) ] doses of approximately 12 rem would be common for a [64 year old] Colorado resident who had normal exposure to dirt and x-rays. Johnston, 597 F.Supp. at 389-90 (internal citations omitted) (citing BEIR III). The effect of radiation exposure upon a human being is controlled by a number of variables. For example, the effects depend “not only on the absorbed dose, but also on the type and energy of the radiation causing the dose.” Chernobyl Report at 20. In addition, the likelihood of observing effects will depend upon the tissue or organ irradiated and the degree of sensitivity of that tissue or organ to radiation. Id. b. Quantifying Dose/Dose Reconstruction When considering the potential biological effects of exposure to ionizing radiation, it is necessary to consider the pathway through which the radiation entered the body. Following any release of radionuclides to atmosphere, people can be exposed via a number of different routes. As the radioactive cloud is dispersed and transported by the prevailing winds, people are initially exposed to radiation by two principal routes: external irradiation from material in the cloud and internal irradiation following inhalation of radioactive material in the air. Subsequently, the contents of the cloud are gradually depleted during its dispersion as radioactive materials are transferred to the ground and water bodies under dry weather conditions, with precipitation or in fog. People may then be exposed and may continue to be exposed by other routes, the three main ones being: external irradiation from the deposited material itself, the inhalation of any material resuspended into the atmosphere, and the transfer of material through the terrestrial and aquatic environment to food and water, which can give rise to internal irradiation. Chernobyl Report at 81. Among other reasons, the pathway of exposure is important because it provides key information regarding potential exposure. For example, where exposure is internal, from ingestion of a radionuclide, exposure will continue for the life of the radionuclide and will be highest in those organs most susceptible to exposure from the radionuclide ingested. See National Resource Council, Radiation Dose Reconstruction for Epidemiologic Uses 41-3 (1995); see infra at 843-844 (discussing authoritative materials upon which this handbook is based). Two categories of effects may be observed following exposure to ionizing radiation: deterministic effects and stochastic effects. Deterministic effects of exposure to radiation arise from cell death. When a threshold number of cells within a given tissue or organ are killed, “there will be clinically observable pathological conditions such as a loss of tissue function or a consequential reaction as the body attempts to repair the damage. If the tissue is vital and is damaged sufficiently, the end result will be death.” Annals of the ICRP, ICRP Publication 60, “1990 Recommendations of the International Commission on Radiological Protection” at 14 (1991) (hereinafter “ICRP 60”). Acute radiation syndrome, for example, is a deterministic effect of radiation exposure. Stochastic effects occur when the irradiated cell is modified rather than killed. Chernobyl Report at 39-40. The modified cell replicates itself, and over time, may develop into cancer. The risk of contracting cancer as a result of radiation exposure increases in relation to the dose of radiation to which a person is exposed. See generally, Chernobyl Report at 40-41 (“[F]atal cancer risk factor following exposure to relatively low doses delivered at low dose rates is smaller than the values assessed for high doses at high dose rates.”); BEIR V at 20-24 (discussing radiobiological concepts impacting on biological consequences of a given dose of radiation). Accordingly, to determine the effect that radiation exposure will have on a person, it is necessary to quantify the dose of the exposure. The following dosimetric quantities are used within the field of health physics to express exposure: Absorbed dose: The amount of radiation energy that is absorbed per kilogram of tissue. It is expressed in grays (Gy). Equivalent dose: The absorbed dose weighted for the harmfulness of different radiations (by radiation weighting factors) to take into account the different types of radiation and their energies. It is expressed in sieverts (Sv), with submultiples of millisieverts (mSv)____ For most practical applications, the radiation weighting factor is unity; that is, the numerical values for absorbed dose and equivalent dose will be equal. Effective dose: The equivalent dose weighted for the susceptibility of harm of different human tissues. It is a (modified) equivalent dose and is also expressed in sieverts. Chernobyl Report at 21. Although uncertainties remain, the last decade has seen tremendous advances in what is known about radiation induced cancers. See BEIR V at 1 (“Since the completion of the 1980 BEIR III report, there have been significant developments in our knowledge of the extent of radiation exposures from natural sources and medical uses as well as new data on the late health effects of radiation in humans____ Furthermore, advanced computational techniques and models for analysis have become available for radiation risk assessment.”). Long term studies on the survivors of Hiroshima and Nagasaki, British akylosing spondylitis patients treated with radiation therapy, and other persons exposed to radiation via nuclear weapons testing or occupational exposures, have increased the body of knowledge regarding the health effects of radiation exposure. See United Nations Committee on the Effects of Atomic Radiation (“UNSCEAR”), “Sources and Effects of Ionizing Radiation” at Appendix F, p. 620 (1993) (hereinafter “UNSCEAR 1993”). Based upon these advances, and relying upon the findings of these authoritative compilations, the National Research Council in 1995 published a comprehensive handbook on the mechanics of dose reconstruction. Radiation Dose Reconstruction for Epidemiologic Uses (1995) (hereinafter “Radiation Dose Reconstruction ”). Radiation Dose Reconstruction focuses on the process of reconstructing a dose from a past exposure to radiation to provide a basis for estimating health risks arising from the exposure. Id at 7. As such, it is well suited to serve as a framework for evaluating the evidence in the captioned matter. The following “steps” are identified in Radiation Dose Reconstruction as integral to any dose reconstruction analysis: *Source term analysis consists of estimating the magnitude of releases to the environment of radionuclides and the periods over which they were released, including episodic releases from nonroutine events. *Pathway analysis examines the transport of released radionuclides through environmental pathways to determine their concentrations in environmental media to which people were exposed. These media include air, surface and groundwater, and soil, among others. *Assessment of radiation doses and risks brings together all of the data on releases, transport, lifestyle and dietary habits, analysis of agricultural and food-distribution practices, and biologic factors, including the use of biologic dosimetry, to determine doses or to corroborate evidence of doses and to estimate the likelihood of disease in the exposed persons. *Examination of epidemiologic considerations takes into account the size and demographic structure of the potentially affected population, the availability and quality of information needed to estimate the dose, the medical information needed, and the feasibility of conducting an investigation that is sufficiently informative and free of bias. *Uncertainty and sensitivity analysis identifies the importance of changes in the parameters and values used to estimate confidence intervals in the overall analysis of the dose reconstruction---- Radiation Dose Reconstruction at 9 (footnote added; emphasis in original). It is also noted that “[h]istoric records are commonly the foundation of a dose reconstruction project, and [that] it is always preferable to use measured data (historic data) rather than models in reconstruction of doses.” Id. at 10. Finally, the report stresses that “[d]os’e reconstruction studies must rely on solid science, state-of-the-art methods, and careful peer review if they are to be viewed as credible. Ultimately, a dose reconstruction study will be judged by the scientific community primarily on the basis of the technical quality of the study and its contribution to science.” Id. at 14. c. Risk Assessment Once a dose reconstruction'analysis is performed, it is possible to make a risk assessment based upon the calculated exposure level. Risk assessments of this nature are made by reference to, among other things, “dose-response curves” which delineate the connection between radiation exposure at various doses and cancer induction. Stated in the most general terms, UNSCEAR and the ICRP recognize the “curve” for solid cancers to be linear, while the “curve” for leukemias is recognized to be linear-quadratic. See BEIR V at 140-44 (“The dose-response relationship for the induction of radiogenic transformation reflects a balance between an increase with dose in the proportion of cells that are transformed and a decrease in cell survival.”); Medical Effects at 82 (explaining linear, quadratic and linear-quadratic dose-response curves). The scientific literature is in agreement that no study has shown a dose-response relationship at doses under 10 rems. See BEIR V at 4-5; Medical Effects at 86 (“there is, in fact, no proven body of data that established an increase in human cancer levels below about 0.1 Gy (10 rad)); see also UNSCEAR 1994 at 50-60 (Annex A) (summarizing the findings of epidemiological studies attempting to establish a dose-response relationship following exposure to low-LET radiation); UNSCEAR 1993 at 676, 679-80 (Annex F); Chernobyl Report at 41 (“statistically significant direct observations in man in homogenous populations ... are available for doses down to about 200 mSv.”). Moreover, at doses below 10 rads, biological markers of dose and exposure become less helpful as indicators. Radiation Dose Reconstruction at 58 (“For retrospective dose reconstruction, it is generally agreed that markers of exposure are not useful below an acute dose of 0.1 Gy (10 rad).”); see generally id. at 51-59. Accordingly, the most that scientists can do is extrapolate and speculate regarding the dose-response relationship at such low levels of exposure. In addition to the dose-response curves, risk assessments must consider a number of factors that could increase or decrease a person’s propensity to develop cancer following radiation exposure. These factors include, but are not limited to: age at the time of exposure, sex, genetic predisposition, whether the individual smokes, and the possibility of exposure to other toxic agents. See Radiation Dose Reconstruction at 48; ICRP 60 at 120-22; EPA Guidelines at 22,-900. Finally, a comprehensive dose assessment depends upon the calculation of an organ dose. Id. at 47 (“The organ dose is especially important when developing doses to compare to site-specific health effects.”) Knowledge of the type of radionuclide to which an individual was exposed is relevant when calculating organ dose. See Allen, 588 F.Supp. at 308 (“Once ingested or inhaled, the degree of exposure actually experienced depends upon the highly variable physical and chemical qualities of each individual radionuclide.”). 3. Principles Relevant to a Nuclear Reactor Accident a. Pressurized Water Reactors The basic principles' associated with the operation of pressurized water reactors (“PWR”) are not at issue in this case (although the specific operation of the TMI-2 PWR during the accident is). An understanding of these basic principles is necessary to understand the release and source term evidence in this case. Plaintiffs, however, have not introduced evidence providing a description of these basic principles. The court’s searching review of the record has revealed one governmental report and one affidavit that explain these principles in layperson’s terms. Since the basic operation of a pressurized water reactor is not at issue in the litigation, the court finds it proper to rely on the following excerpt from the Daniel affidavit for its educational value: A nuclear power plant produces heat energy that is converted to steam in a boiler. The steam is used to turn a turbine, which is connected to an electrical generator. The heat is produced in a steel vessel called a reactor, since nuclear reactions are contained within the vessel. In a reactor design such as TMI-2, uranium fuel is used to provide the heat energy. The fuel is formed into a ceramic pellet approximately % inch in diameter, and about a half-inch long. These pellets are stacked into metal rods called fuel pins, and the fuel pins are arranged into square arrays called fuel assemblies. The fuel assemblies are approximately 12 feet in height, and are collectively referred to as the reactor core contained in the reactor vessel. Within the fuel assemblies are several tubes which have instruments to monitor the reactor and other tubes that contain control rods which “speed up” or “slow down” the reaction. The fuel pellets are protected from direct contact with water in the core by the rods made of zirconium, which is sometimes called the fuel cladding— In a pressurized water reactor, such as TMI-2, there are three cooling circuits. The primary circuit is a closed loop circuit and circulates water through the reactor core. This circuit is called the primary coolant or reactor coolant. The reactor coolant is maintained at a pressure that is high enough to prevent it from boiling. The reactor coolant picks up the heat from the fission reaction and carries it out of the core to two steam generators (or boilers). These are tanks approximately 35 feet tall in which the primary water passes through a large number of small diameter tubes, transferring heat to water flowing in the secondary circuit, which is outside these tubes. Water in the secondary circuit is maintained at a lower pressure and boils to make steam which occupies much more volume than water. That steam therefore “pushes” itself out at high velocity to the turbine-generator unit. The steam in the secondary circuit is called the main steam system. The steam passes from the turbine to a condenser which is cooled in turn by the third circuit, water from the cooling towers. Water collected in the condenser is pumped back to the steam generators. The water in this portion of the secondary circuit is called feedwater. The water in the primary loop is kept from boiling by keeping it under high pressure — normally about 2200 pounds per square inch. A large vessel connected to the primary loop called the pressurizer is used to maintain this pressure. The pressurizer is normally about half full of water, with a steam cushion in the top half. As the water in the primary loop heats up or cools down, it expands or contracts by many hundreds of cubic feet. The steam cushion in the pressurizer takes up the slack, while maintaining pressure on the reactor coolant water. The control system adjusts the pressure exerted by the pressurizer by controlling the temperature of the water in the pressurizer with electric heaters, and with a cooling water spray. A relief valve is provided on the pressurizer to prevent over-pressurizing the system. This valve is a power-operated relief valve, or PORV. If this valve is opened to relieve the excess pressure, the steam or water flows to a drain tank. If the drain tank becomes over filled, a rupture disk is provided on the tank to relieve pressure. The relief valve has a backup, which is called a block valve. Additionally, two large safety valves provide protection against larger transients. The reactor coolant may have chemicals added to it for fine adjustment of the nuclear reaction taking place in the reactor core, and to remove any impurities that may have collected in the coolant. During power operation, a small flow of reactor coolant is bled off from the reactor coolant system and passed through a series of filters and demineralizers. If any additional water is needed in the reactor coolant system, it is added from water stored in tanks located in the auxiliary building. The system that collects water from the reactor coolant system and adds water to the reactor coolant system is called the makeup purification system. Gases collected from the reactor coolant system are collected in tanks called waste gas decay tanks____ The reactor vessel, pressurizer, associated piping, reactor coolant pumps, and steam generators are called the reactor coolant system. The reactor vessel is a steel pressure vessel with walls that are 8¡¿ inches thick, surrounded by a concrete and steel shield over 8 feet thick. The reactor coolant system is housed in a cylindrical building, which is actually a large pressure vessel called the reactor building. The turbine, condenser, and electrical generator are housed in a concrete and steel building called the turbine building. Auxiliary systems used to process and maintain the chemical and radiological purity of the reactor coolant are housed in what is called the auxiliary building. The fuel handling building, as its name implies, contains storage facilities for new and used fuel. The used fuel, after removal from the reactor core, is stored underwater in the spent fuel pool. The plant operators monitor and maintain control of the various plant systems from a central control room located in the control service building. 4/28/93 Aff. of John Daniel at ¶ 17, ¶¶ 19-25 (emphasis in original); see also Mitchell Rogovin, Nuclear Reg. Comm’n Inquiry Group, NUREG/CR-1250, TMI Report to the Commissioners and to the Public 10-13 (1980) (section titled “Primer on the Pressurized Water Reactor: From A-Loop to Zircaloy”) (hereinafter “Rogovin Report”). b. Plume Dispersion Once fission product noble gases are released into the atmosphere, the path that they travel and the degree of concentration that they maintain over a given distance can be determined through the use of dispersion modeling and the science of meteorology. “Atmospheric dispersion modeling is really the development of mathematical relationships that describe how something that’s from material that’s released into the atmosphere is dispersed as it travels downwind.” (11/13/95 Tr. at 149 (testimony of Keith Woodard).) The following explanation of basic dispersion modeling (with specific attention paid to a model used in evaluating the TMI plume) is illustrative: The basic function of the model is to calculate dispersion (dilution) of the released material as it travels downwind and to estimate the resulting concentrations of this material at ground level. The material is considered to form a “plume” as it is transported downwind. This plume trajectory (or travel direction) changes, depending on meteorological measurements of wind speed and direction updated every 15 minutes. The plume size depends on turbulence. As turbulence increases, the plume becomes larger and more dilute. Turbulence is based on vertical temperature difference measurements from the meteorological tower. Generally, turbulence increases in the daytime and decreases at night. The model assumes an initial elevation and plume spread depending on the effects nearby buildings have on the wind streamlines in relation to the release location (the plant vent in this case). Depending on the flow rate from the plant vent and the wind speed, the plume is divided into small segments called spatial intervals according to the travel distance for the 15-minute period. Plume dispersion is estimated at the center of each segment based on the weather measurements. The time it takes for the cloud to arrive at, and to traverse, each spatial interval is calculated using the average wind speed for that interval. Whenever there is a change in stability, the new spatial interval rate of growth is based on the new stability. (1/15/93 Aff. of Keith Woodard at ¶¶ 14-15) C. Factual Background The accident at TMI-2 began ... at 4 a.m. on March 28[, 1979]. A minor malfunction, or transient, in the nonnuclear part of the system would evolve a series of automated responses in the reactor’s coolant system, and during all of this, the relief valve on top of a piece of equipment called “the pressurizer” would become stuck open. Owing to continued misreading of the symptoms by the operators over a 2/4— hour period before the relief valve was closed and the turning off of an automatic emergency cooling system, the reactor core would become partially uncovered and severely damaged. It would be another 12 hours before the plant crew and the engineers from GPU Service Company would concur in effective corrective action. Rogovin Report at 3-4. During the incident, radiation was emitted from the Unit-2 reactor. The actual amount emitted, and whether Plaintiffs were exposed to the emissions, are central issues in this case. According to the Rogovin Report, “approximately 2.5 million curies of radioactive noble gases and 15 curies of radioiodines were released---These releases resulted in an average dose of 1.4 mrem to the approximately two million people in the site area.” Rogovin Report at 153. Plaintiffs, to the contrary, contend that area residents were exposed to in excess of 100 rems of radiation. Defendants have conceded that releases at the plant boundaries exceeded normal levels of background radiation, In re TMI Cases Consolidated II, 67 F.3d 1103, 1118 (3d Cir.1995). However, Defendants deny that appreciable or dangerous levels of radiation reached populated areas. Plaintiffs’ theory of the case is that a narrow yet highly concentrated plume of radioactive noble gases (primarily iodine and xenon-133) was carried away from the TMI plant during one or all of three hypothesized “blowout” periods. Plaintiffs’ argue that prevailing weather conditions permitted the plume to drift through the atmosphere, moving between the thermoluminescent dosimeters (“TLDs”) which composed the TMI Radiation Environmental Monitoring Program (“REMP”), and caused the plume to remain highly concentrated for a significant distance. Plaintiffs contend that the plume made contact with higher land elevations within the TMI area, and that persons residing in areas of plume touchdown were exposed to harmful levels of ionizing radiation. Plaintiffs claim that they have developed radiation induced neoplasms as a result of their exposure to ionizing radiation during the TMI incident. The parties agree that the following test Plaintiffs have been diag-' nosed with the illnesses listed: Paula Obercash: acute lymphocytic leukemia Gary ViHella: chronic myelogenous leukemia Leo Beam: chronic myelogenous leukemia Joseph Gaughan: thyroid cancer Lori Dolan: Hurthle cell carcinoma Jolene Peterson: thyroid adenoma Ronald Ward: osteogenic sarcoma (right leg) Pearl Hickemell: .breast cancer Ethelda Hilt: adenocarcinoma of the ovaries Kenneth Putt: bladder cancer, acoustic neuroma. Defendants contend that Plaintiffs have failed to establish that any of the test Plaintiffs’ neoplasms are causally related to radiation exposure during the TMI incident. II. Legal Standards The instant motion for summary judgment will be considered pursuant to Rule 56 of the Federal Rules of Civil Procedure. Summary judgment is appropriate where there are no remaining issues of material fact to be decided, and one party is entitled to judgment as a matter of law. Hankins v. Temple University, 829 F.2d 437, 440 (3d Cir.1987). In examining Rule 56 motions, the court must consider “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251-52, 106 S.Ct. 2505, 2512, 91 L.Ed.2d 202 (1986). The parties’ burdens at summary judgment may be described in the following manner: once the moving party has shown an absence of evidence to support the claims of the nonmoving party, the nonmoving party must do more than simply sit back and rest on the allegations of her complaint. She must “go beyond the pleadings and by her own affidavits, or by the ‘depositions, answers to interrogatories, and admissions on the file,’ designate ‘specific facts showing that there is a genuine issue for trial’” Celotex Corp. v. Catrett, 477 U.S. 317, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). If the nonmovant bears the burden of persuasion at trial, the moving party may meet its burden by showing that the evidentiary materials of record, if reduced to admissible form, would be insufficient to carry the non-movant’s burden at trial. Chipollini v. Spencer Gifts, Inc., 814 F.2d 893, 896 (3d Cir.), cert. dismissed, 483 U.S. 1052, 108 S.Ct. 26, 97 L.Ed.2d 815 (1987). “The mere existence of a scintilla of evidence in support of the plaintiffs position will be insufficient; there must be evidence on which the jury could reasonably find for the plaintiff.” Anderson, 477 U.S. at 252, 106 S.Ct. at 2512. In a ease dependent upon expert scientific testimony, the court must determine whether the admissible scientific testimony is sufficient to carry the nonmovant’s burden at trial. The Supreme Court, in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 595, 113 S.Ct. 2786, 2798, 125 L.Ed.2d 469 (1993), noted as follows: in the event the trial court concludes that the scintilla of evidence presented supporting a position is insufficient to allow a reasonable jury to conclude that the position more likely than not is true, the court remains free to direct a judgment ..., and likewise to grant summary judgment____ These conventional devices, rather than wholesale exclusion under an uncompromising “general acceptance” test, are the appropriate safeguards where the basis of scientific testimony meets the standards of Rule 702. Id.; see also DeLuca v. Merrell Dow Pharmaceuticals, Inc., 911 F.2d 941, 958 (3d Cir. 1990) (“[the] court ... must ultimately determine whether the admissible evidence tendered by the party having the burden of proof on an issue is sufficient to permit a rational factfinder to find for that party on that issue under the appropriate burden of proof’); Wade-Greaux v. Whitehall Laborar tones, 874 F.Supp. 1441, 1485 (D.V.I.) (“Even when a court determines that expert opinion evidence is admissible, it must still determine whether it would be sufficient to sustain a jury verdict in plaintiffs favor.”), aff'd, 46 F.3d 1120 (3d Cir.1994); cf. Ambrosini v. Upjohn Co., 1995 WL 637650 at *1 n. 1 (D.D.C. October 18, 1995) (“The [District of Columbia] Court of Appeals has stressed that the admissibility of an expert’s opinion is ‘separate and distinct from the issue whether the testimony is sufficient to withstand a motion for summary judgment.’” (citation omitted)). III. Discussion In this section, the court will first discuss its examination of the record evidence supporting both Defendants’ and Plaintiffs’ cases. Next, the court will explain the elements of Plaintiffs’ prima facie case, and discuss the degree to which Plaintiffs have presented evidence in support of that case. Finally, the court will discuss its finding that Plaintiffs have failed to present evidence sufficient to create a material factual dispute on the issue of dose. At the outset, it is important to note that the scientific evidence must be viewed through the framework set forth by the court in the scientific background section of this memorandum of law. Thus, the court must first examine whether source term evidence has been presented to support the theory that there was a release from the plant during the accident. Next, the court must determine whether there is evidence demonstrating whether Plaintiffs were exposed to the release, and if so, whether there is evidence illustrating the pathways through which Plaintiffs were exposed. Finally, the court will evaluate whether the record evidence is sufficient to support the inference that radiation exposure induced the test Plaintiffs’ subsequent health effects (neoplasms). A. The Defendants’ Case Defendants attack Plaintiffs’ evidence of exposure and dose arguing that, reduced to admissible form, the evidence is insufficient for Plaintiffs to meet their burden of proof on the issue of causation at trial. (Defs.’ Mem. in Supp. of Motn. for Summ.J. at 126-32 (hereinafter “Defs.’ Mem. in Supp.”).) 1. Exposure/Dose Evidence Defendants have offered John Daniel, a nuclear engineer, as their source term expert. Daniel “was engaged by counsel for defendants to study the sequence of events, possible pathways of releases, and magnitude of releases during the TMI accident.” (Defs.’ Mem. in Supp. at 42 (footnote omitted).) Daniel will testify regarding the in-depth analysis he performed on all relevant plant data and the “time line” of key events that he derived from that analysis. According to Defendants, the time line will chronicle the “events that occasioned the transport of radioactivity to the Aux[iliary] Building and the release of that radioactivity into the Aux[iliary] Building atmosphere.” (Defs.’ Mem. in Supp. at 48.) According to Daniel’s calculations: approximately 17 million curies of noble gas were transported to the auxiliary building by all pathways during the accident, of which approximately 14 million curies were transported during the first 48 hours. Of the 17 million curies transported to the auxiliary building, 8.6 million curies were released to the environment by all pathways during the period 4:00 A.M. on March 28th, 1979 to 6:00 A.M. April 7th, 1979. This quantity represents more than 99% of the total activity released from TMI-2 as a result of the accident. The predominant radionuclide release to the environment was Xe-133. The remaining 8.4 million curies of noble gas were either transferred back into the reactor budding by the plant operators, or were contained in tanks in the auxiliary building. (4/28/93 Aff. of John Daniel at ¶ 35 (footnote added).) After examining all potential pathways for release, Daniel reached the conclusion that the pathway for fission products from the coolant to the reactor building was through the power-operated relief valve (“PORV”). (4/28/93 Daniel Report at 99.) “[T]he major pathway for fission product transport [from the reactor building] to the auxiliary building was through the letdown piping of the makeup and purification system.” (4/28/93 Daniel Report at 33.) It is through this pathway that approximately 17 million curies were transferred to the auxiliary building; and, of that 17 million, approximately 8.6 million were released to the environment. (Id. at 34.) Daniel concludes that the primary release pathway from the auxiliary building to the environment was through plant ventilation systems. (Id. at 60.) In addition to deteraiining how radioactive noble gases were released into the atmosphere, Daniel computed the core inventory of fission products to determine the quantities of specific radionuclides that were released into the environment. Daniel utilized the LOR2 computer code to calculate the core inventory. (Id. at 81.) According to his report, Daniel found this code to be the most accurate because it accounted for the concentration of boron in the reactor coolant during periods of irradiation, “factored in the actual operating history of the TMI-2 core, [and] accounted for the different power levels that the actual core experienced.” (Id.) Table 3.2 of the 4/28/93 Daniel report provides a breakdown of the core inventory of selected fission products at the time of reactor shutdown. (Id. at 83.) By calculating the core inventory, Daniel was able to determine which noble gases were transported into the auxiliary building and then to the environment. Defendants rely upon the proffered testimony of Keith Woodard to explain how the approximately 9 million curies of radioactive noble gases released from the plant were dispersed into the environment. In addition, based upon his dispersion analysis, Woodard has made individual whole body dose calculations for each of the ten test Plaintiffs. Woodard is the vice president of Pickard, Lowe & Garrick, Inc. (“PLG”), a consulting/engineering firm specializing in the field of meteorological dispersion studies. (1/15/93 Aff. of Keith Woodard at ¶ 1.) During the TMI accident, Woodard worked with emergency response teams to perform dose assessments to support the on-site response organization. (Id. at ¶ 4.) Additionally, following the accident, Woodard studied offsite exposures and reported his findings in a document titled, “Assessment of Offsite Radiation Doses from the Three Mile Island Unit 2 Accident,” TDR-TMI-116, Revision 0 (July 31, 1979) (hereinafter “TDR-TMI-116”). (Id. at ¶ 5.) At the request of counsel for Defendants, Woodard performed two separate studies. The first study utilizes the Daniel source term and the Meteorological Information and Dose Assessment System dispersion model (“MIDAS”) to calculate the percentage of the NRC’s Maximum Permissible Concentration (“MPC”) in the TMI area. Woodard also calculates whole body dose levels using the Daniel source term. The second study also uses MIDAS, but uses the source term methodology employed in TDR-TMI-116 rather than the Daniel source term. (Id. at ¶8.) Woodard’s studies both indicate that dangerous levels of radiation (e.g. greater than the NRC MPC’s for one year) did not reach populated areas beyond the plant boundaries. Rather, Woodard contends, the highest concentrations of radiation were found on the Island itself, in a portion of the Susquehanna River, and on uninhabited islands in the river. (Id. at ¶¶ 22-23.) Woodard states that the outcomes of his studies are confirmed by comparing them with off-site TLD measurements and with the inventory of noble gases found in the containment and fuel following the accident. (Id. at ¶¶ 30-31.) Finally, based upon his dispersion calculations, Woodard calculated whole body doses for each of the test Plaintiffs. Viewing the facts in a light most favorable to Plaintiffs, the court will presume Woodard’s “high” dose estimates to be true. According to those estimates, only one of the ten test Plaintiffs was exposed to a dose greater than 25 mrem. That Plaintiff, Jolene Peterson, was exposed to an estimated maximum dose of 75 mrem. Four of the test Plaintiffs, Pearl Hickemell, Ethelda Hilt, Leo Beam and Ronald Ward, were exposed to estimated maximum doses under 10 mrem. The remaining test Plaintiffs, Gary Villella, Lori Dolan, Joseph Gaughan and Paula Obercash, were exposed to' estimated maximum doses of between 15 and 25 mrem. These dose calculations are based upon the Daniel source term, do not make any attempt to adjust for possible shielding, and account for changes in each Plaintiff’s physical location over time. (7/12/95 Woodard Report at 39.) Defendants also rely on a number of governmental reports in support of their position on the issue of dose. The first of these is the report of the Ad Hoc Population Dose Assessment Group. This report “is an assessment of the health impact on the approximately 2 million offsite residents within 50 miles of the Three Mile Island Nuclear Station from the dose received by the entire population (collective dose).” Ad Hoe Population Dose Assessment Group, “Population Dose and Health Impact of the Accident at the Three Mile Island Nuclear Station” at preface (May 10,1979) (D-X-33) (hereinafter “Ad Hoc Group Report”). The Ad Hoc Group relied upon TLD data and onsite meteorological data to compile conservative dose estimates. Id. at 1-2. Noting that “any approach to assessing the collective dose depends strongly on a relatively small number of measurements,” id. at 41, the Ad Hoc Group nevertheless found that “the data do allow reasonable estimates of the collective dose to be made.” Id. (footnote added). It is presumed that the greatest degree of exposure came from xenon. Id. at 11 (“The principal radioactive materials released to the environment appear to be xenon-133 (half-life 5.3 days) and xenon-135 (half-life 9.2 hours) and traces of radioactive iodine, primarily iodine-131 (half-life 8.0 days)”). Milk and food samples taken during the period of March 31, 1979 through April 4, 1979, one week after the accident, confirm this hypothesis: The maximum concentration [of iodine] measured in milk (41pCi/liter in goat’s milk, 36 pCi/liter in cow’s milk) was 300 times lower than the level at which the Food and Drug Administration (FDA) would recommend that cows be removed from contaminated pasture. Cesium-137 was also detected in milk, but at concentrations expected from residual fallout from previous atmospheric weapons testing. No reactor-produced radioactivity has been found in any of the 377food samples collected between March 29 and April 30 by the FDA Id. at 7 (emphasis added). The report concludes that the “predominant exposures to offsite individuals ... [are] in the NNW [north-northwest], ENE [east-northeast], and SSE [south-southeast] sectors.” Id. at 44. The east-northeast sector registered the highest cumulative dose — 83 mrem. Id. Further, the report predicted the following with respect to potential health effects of the TMI accident: The projected total number of fatal cancers is less than 1 (0.7). The additional number of non-fatal cancers is also less than 1 (0.7). The additional number of genetic effects for all generations is also less than 1 (0.7)____ All of these values are small compared to either the existing annual incidence of similar effects or the potential effects estimated to result from natural background radiation____ Comparing the total potential health impact of the accident with the estimated lifetime natural risk indicates that these effects, if they were to occur, would not be discernable. The uncertainties in the risk from low-level ionizing radiation would not alter this conclusion. Id. at 60. Next, Defendants point to the Report of the Task Group on Health Physics and Dosimetry of the President’s Commission on the Three Mile Island Accident. The Commission’s Task Group used available TLD data to estimate exposure levels for the areas surrounding TMI. The Commission concluded as follows: Persons within a 2-mile radius of the plant probably received the highest doses. The dose to the one person known to have been on one of the nearby islands, for about 9}£ hours during the first few days of the accident, is estimated to be about 50 miUirems (mrem). In addition, about 260 people living mostly on the east bank of the river may each have received between 20 an 70 mrem. All other people probably received less than 20 mrem. President’s Commission, “Report of the Task Group on Health Physics and Dosimetry” at 16 (1979) (D-X-48) (hereinafter “Task Group Report”). In addition to calculating these short-range dose projections, the Task Group also used available plant data to estimate a source term and determine maximum doses for a fifty mile radius surrounding TMI. Id. at 139-47. In terms of individual doses, the highest possible doses were assigned to those persons residing within a one-mile radius of the plant. Id. at 117. These persons were estimated to have been exposed to a maximum dose of 58.6 mrem. Id. Persons within a 5 to 10 mile radius of the plant had an estimated maximum dose of 5.2 mrem. Id. Finally, persons living within a 40 to 50 mile radius were estimated to have been exposed to a maximum dose of 0.28 mrem. Id. The NRC also commissioned its own study of the TMI accident. See generally, Rogovin Report, supra. Following their extensive review of radiological and health-related conditions before, during and after the accident, see Rogovin Report, Vol. II, Part 2 at 341 (summarizing inquiry conducted and data relied upon), the NRC’s Special Inquiry Group reached the following conclusion regarding releases during the TMI accident: There were numerous deficiencies related to radiation protection and radiological health; however, few, if any, of the deficiencies were causal factors in the TMI-2 accident____ The radiological consequences of the releases of radioactive material from TMI-2 into the environment are minimal at worst and may be nonexistent. Therefore, public concern regarding the effects of releases of radioactive materials from TMI-2 is not warranted. Id. at 342. Noting that “[t]he buildings and equipment at the Three Mile Island Station provided substantial mitigation of the release of radioactive material to the environment,” id at 360, the NRC found that: the quantity of radioactive material ... released in liquid effluents as a result of the accident is not significant ... [and] the quantity of radioactive material released in gaseous effluents due to the accident consisted of 15 Ci of I[odine-131] and 2.4 million Ci of noble gases. Id. at 362. In addition, the report found that although not perfect, the TLDs in place at the time of the accident were “adequate to characterize the radiation levels in the environment attributable to the accident.” Id. at 395; see id. at 399, 407. With respect to its analysis of potential health effects related to the accident, the NRC reviewed existing governmental reports. Id. at 399. Indicating that “[t]he studies were independently performed with different methodologies, yet arrived at similar population dose estimates,” id., the NRC “deemed it unnecessary to perform additional independent analysis of the raw data.” Id. The NRC found the findings of both the Ad Hoe Group and the President’s Commission Task Group to be accurate and verifiable. Id. at 400. Based upon these findings, the NRC concluded that “the maximum offsite individual dose was less than 100 mrem.” Id. Finally, the report indicates that it is “extremely unlikely” that any individual will suffer future adverse health effects as a result of the accident. Id. at 408. Next, Defendants direct the court’s attention to a study commissioned by the Pennsylvania Department of Health (PADOH) in the wake of the TMI accident. Proceedings of the Pennsylvania Academy of Sciences, 57:99-102 (1983) (reporting the PADOH study) (D-X-l) (hereinafter “Proceedings”). In this study, PADOH performed dose assessments on each of the 34,000 members of the 13,000 households located within a five mile radius of TMI. Id. at 99. In June of 1979, a special census was conducted to identify the households included in the study. Id. at 100. “The TMI Population Registry resulting from the census effort has been estimated to be 95% complete.” Id. Using a methodology similar to that used in TDR-TMI-116, id., the PADOH study estimated both maximum and likely dose estimates for a five mile radius around TMI. According to the study, the highest possible maximum dose was 165 mrem, and the highest likely dose was 80 mrem. Id. at 101. The final study upon whic