ML19305B712
| ML19305B712 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/11/1980 |
| From: | Beyea J PRINCETON UNIV., PRINCETON, NJ |
| To: | |
| Shared Package | |
| ML19305B707 | List: |
| References | |
| FRN-44FR75167, RULE-PR-50 NUDOCS 8003200126 | |
| Download: ML19305B712 (49) | |
Text
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The Impact on New York City of Reactor Accidents atIndianPolnt Statement to the 4
New York City Council June 11,1979 (CorrectedJune 20, 1979)
Jan Beyea Research Staff Center for Energy.and Environmental Studies Princeton University 80082oo i%
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%9 Because there is so much uncertainty about safety aspects of nuclear power, and because such passion exists over nuclear policy, technical opinions about the dangers of Indian Point vary enannously.
In such a confusing situ-ation it helps to know the background and temperanent of who is speaking.
Therefore, I will begin my statement with some remarks about my experience in the nuclear safety field.
I am a nuclear physicist who has been working for the last three years as a research staff member at Princeton University's Center for Energy and Environ-mental Studies.
(I have attached a list of the studies I have been asked to make about the consequences of accidents at nuclear facilities around the world.)
Of particular relevance to today's proceedings are 1) the detailed study of' accidents at the BarsebEck reactor which I carried out for the Swedish Energy Coninission,
- 2) the dose-prediction computer code, which I wrote fpr the N.J.
Department of Environmental Protection to aid in their planning for reactor accidents,
- 3) the analysis I made of the proposed Jamesport reactor site in connection with a case before the N.Y. State Siting Board, and 4)thestudy of potential accidents involving spent-fuel rods carried out for the state of Lower Saxony in West Germany.
By temperament, I tend to be.sceptical about the ability of scientists and engineers to guarantee anything about systems which have not been tested in operation.
This prediliction has led me in the past to strongly criticize the optimism of government reports such as WASH-l?00 (the Rasmussen report) and to view nuclear power as a potentially dangerous technology.
Long.before Three Mile Island, I stated that the probability of accidents might be significant and called, as a result, for accident mitigatory measures in my European studies l
(similar to those which my colleague Frank von Hippel and his coautnors ir. the l
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American Physical Society Study Group on Light Water Reactor Safety first proposed for the U.S.I).
For instance, in my Swedish study I suggested that serious emergency planning be carried out for cities such as Malmo (which lies within 10 miles of the BarsebSck reactor) and Copenhagen (15 miles away) something which seened radical to nuclear proponents, and engendered much criticism, before Three Mile Island.
This critical public posture has not endeared me to the nuclear establish-ment.
On the other hand, the fact that I refuse to call for the shutdown of any particular reactor, without knowing the particular substitute which will replace it', has not endeared me to the anti-nuclear movement either.
Having located myself for you within the nuclear debate, let me turn to rqy technical studies of accidents at Indian Point.
I will discuss 1)the probability of serious accidents at Indian Point, 2) the consequences of such accidents for residents of New York City, and 3) actions that the City and State might take to reduce the consequences of such accidents.
I have two major recomendations to make.
First, that a task force be convened to outline the elenents of an emergency plan suitable for the City.
Second, that a study of alternative ~s to Indian Point be funded, Accident Probabilities It is now clear that the nuclear industry has failed to produce a system with a low probability of catastrophic failure, The Brown's Ferry Fire, in
'which a workman's t'est candle almost caused a disaster, and the Three Mile Island accident, in which only the containment barrier retained its integrity, indicate that unsuspected failure modes have raised the ;.robability of bad accidents perhaps a thousand times higher than assumed at the start of the l
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nuclear program.2 The assurances given to the public over the years by technical people were based on incomplete analysis and optimism.3 The fact that unsuspected failure modes are important at the early stages of a technology is nothing new. Trial and error is the key to being scientific.' Onel' earns from one's mistakes and corrects the design accordingly.'
I have no doubt that after five meltdowns we will have much safer reactors.
The question is whether we can afford to learn by trial and error in the' case of nuclear technology, and whether we want to experiment with reactors close to population centers such as at Indian Point.
I arr aware that many people find it difficult to believe that scientists ano engineers can make disastrous technological mistakes, perhaps because they see the fruits of successful technology all around them and do not see the scores of failures which preceded the successes.
Surprisingly, avid defenders of nuclear technology can accept the existence of human error on the part of operators, but seemingly cannot accept human error on the part of designers.
In fact, however, failure to properly anticipate operator error is in itself a design fault.
Even though p,ast subjective assessments of reactor accident probabilities can no longer be believed, it is possible to rely on another fonn of statistical estimation, namely estimating the frequency of future events based on their frequency in the past.
Virtually everyone admits that the Brown's Ferry fire and the Three Mile Island incident were in the class of
" serious accidents".
Most objective people, I believe, would agree that this class of accident'sho:ild trigger emergency plans -- at least to the extent of notifying authorities and mobilizing emergency personnel and supplies.
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4 These two incidents can be used as indicators of the frequency at which energency plans will be called upon in the future:
The fact that two accidents of this class have occurred in 400 cumulative reactor-years of operation gives us an estimate of the frequency of such events in the future of one in every 200 react r-years.4 Assuming that the past is a guide to the future, we can extrapolate these results to two reactors at Indian Point, and predict a 30%
chance of triggering emergency responses once in the next 30 years.
- However, this approach can be criticized on the grcunds that it does not take into account the experience gained from Brown's Ferry and from Three Mile Island.
Although I am sceptical that the failure modes revealed by those accidents will be completely eliminated by N.R.C. recommendations, I will assume that it will happen in order that my analysis not be vulnerable on this point.
I will assume that half of the unsuspected failure modes have been found already in these previous accidents and will be eliminated soon, and that only two more remain to be found.
Then my predic' tion drops by half to 15%.
A 15% chance of triggering an area wide emergency plan is not trivial.
It demonstrates.to me that New York City needs a detailed contingency plan, if for no other reason than to help prevent panic in case of a prolonged scare such as~
occurred at Three Mile Island.
Such a plan is not yet required by Federal law.
It is up to the City Council, the Mayor, the State Legislature, and the Governor to act now if a plan is to be developed in the near future.
So far I have discussed accidents in which a large release does not occur.
A statistical base'is not available to indicate the chances that an event in the " serious class" would lead to a significant release of radioactivity.
However, the fact that a substantial fraction of the iodine and cesitra in the 4
Three Mile Island case escaped into the containment, the last barrier to the environment, does not engender confidence in the ability of present designs to prevent rel~ eases to the atmosphere.
If forced to guess, I would predict that one in ten of these serious accidents would lead to a large release.
This means, in'cidentially, that I expect a large release of radioactivity to occur-somewhere in the U.S. in the next 30 years.
This release could occur as a result of the next Brown's Ferry or Three Mile Island event, however, as easily as during the tenth.
In ordo c to be prudent, therefore, we should develop our contingency plans on the presumption that there is a sig'nifichnt chance of a large release at. Indian Point in the next thirty years.
Now the wind does not always blow towards the City.
If the radioactivity were released in a short burst, there would be about a 1 in 5 chance of the City being caught downwind.
(See Table I.)
If the release took days, as might happen in an accident less severe than a meltdown, then the probability of city residents receiving some exposure would be considerably higher due to wind wander -- although the expected doses would be considerably reduced.
I have summarized these probability estimates in Table II. The " bottom line", even. from a pessimistic viewpoint, is that New York City will probably never be disastrously affected by Indian Point.
Nevertheless, there is a non-negligible chance of a major release which could affect the City.
What would be the consequences of such an accident?
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i v Consequences of an Accident at Indian Point Note that for a major release of radioactivity to the atmosphere to occur, the reactor containment building must fail to isolate, be broken by an explosion, or fail due to gas o /erpressure.
(None of these events happened at Three Mile Island so there was no large release.)
Figure I shows a side view of the radioactive plume leaving the reactor.
Figure II shows a top view, indicating that the bulk of the effects are con-tained in a wedge with its apex at the reactor spreading out in the downwind direction.
People caught. downwind in the plume would receive radiation doses immediately from the cloud overhead and a continuing dose from radioactivity inhaled during plume passage.
Buildings offer some shielding from cloud shine, but not from inhalation unless the air is filtered or managed in some other way.0 After the plume passed by, radiation would still be present in the area due to radioactive fallout stuck to ground and building surfaces.
The ground radioactivity decreases naturally due to radioactive decay, but residual cesium and strontium, with half lives around 30 years, would cause
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cancer deaths for periods of time measured in decades.
It is the cesium and strontium which are ordinarily considered to be the principal long-tem land contaminants.
Table III indicates in more detail the time frame of received doses.
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All effects from radiation doses do not occur at the time the doses are received.
The time frame can be divided into two periods, "imediate" and "l ong -term".
(See Table IV.)
Sicknessanddeathwithintwomonthsfromradiation) illness would be a ris'k for people caught in very high dose regions (more than
_7_
\\
100 rem to the whole body). The chances of such high doses coccurring in New York City are low and would require unusual meteorological conditions.
Even if there were an accident, and even if the wind were blowing towards the City, there would only be about a 1-in-10 chance of early death.6,7 The long-term effects associated with lower radiation doses include increased rates of cancer (both fatal and non-fatal), and both developmental and genetic birth defects.
The cancers and genetic defects would appear in the exposed population during a period of decades after the accident.
Since moderate and low doses can produce these effects, although at a rate which is ordinarily assumed to decline in proportion to the dose, some long-tenn effects would inevitably occur in the city should the wind be blowing this way.
The magnitude of doses received would depend upon meteorological canditions and the quantities of radioactivity released.. I shall show only doses calculated for typical meteorological conditions and shall consider two accidents.
The first accident assumes c 5% release of iodine (and, of less significance, a 60%
release of the noble gasses), similar to what might have happened at Three Mile Island had the containment building failed to isolate.
The second accident assumes a release corresponding to a meltdown with failure of the containment.
I have assumed a release of radioactivity and meteorological assumptions consistent with the Nuclear Regulatory Coranission's Reactor Safety Study.0 Roderate Release Case:
To show the areas affected by the accident,I have prepared Figure III which shows contours for one wind direction indicating the areas in which thyroid doses would equal or exceed certain values..For simplicity I will focus on doses 35
't miles downwind from the accident (the distance from Indian Point to Central Part). Table Va -shows the doses calculated for typical meteorological conditions.
Unless there were many days warning, I doubt there would be much chance of evacuating people before the plume passed by.
This means that the inhalation and
" cloud shine" doses would be unavoidable.
(If thyroid-blocking pills were avail-able, the thyroid dose could be reduced.significantly.) Table Vb shows some of the expected health consequences from the unavoidable doses.
Although the exact number of people exposed in the City would depend on the wind direction, a reason-able number to use in the calculations of health effects would be one million expose people.
In such a case 20,000 to 100,000 cases of thyroid nodules would be expected After passage of the plume, a decision would have to be made about evacuating remaining persons in order to prevent the continuing smaller,but cumulative, doses which would be received from subsequent exposure to contaminated areas.-
For this accident, the first two months would constitute the important time period.
Table Va indicates that an additional 1 rem dose would be accumulated in the time period beginning one week after the accident and ending two months later.
Tiieindividual risk from staying would be small - corresponding to the expected dose during ten years exposure to natural sources of radiation - and the economic cost of relocat-ing people and halting business activity would be enormous.
Consequently, I doubt that the decision would be made to evacuate.
It must be noted however, that my ground dose prediction is very uncertain and could easily be a factor of 5 too high or low.
For a wind direction exposing one million New York City residents, Table Vb indicates t, hat 1400 to 8000 cancers would eventually develop, with 200 to 1600 of them being fatal.
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PWR2 Accident i
Let -us now turn to the catastrophic failure case, a "PWR2" accident in the terminology of the Rasmussen Report.
It is not the worst possible accident in that study, but close to it. Table VIa shows doses at 35 miles under typical meteorological conditions.
Once again it is assumed that the wind is blowing towards New York City.
If not, some other coccunity would be exposed.
Figures IV, V, and VI show area contours for various doses.
Table VIb shows the major health consequences fran the inhalation and cloud shine doses plus one day's exposure to contaminated ground. Most of the exposed population would develop thyroid nodules which would require surgical treatment.
Table VIa indicates that evacuation would likely be instituted even after plume passage because the doses received from even a 7 day residence time would be in excess of 28 rem.
(An optimistic evacuation time of one day was assumed in Table VIa in order not to overstate the health consequences.
Even then, 600 to 6000 can.cer deaths are predicted to result for a wind direction exposing one million New Yorkers.)
In some areas, the land would be so highly contaminated that residents could not go back for decades in the absence of highly effective decontamination procedures.
Figure VII shows the long-teria land contamination areas.
(I have used a threshold for land contamination corresponding to a few tenths of a percent risk of cancer death resulting from thirty years residence on the land.9)
It is very difficult to predict what action would be taken after the accident, what levels of. contamination would be accepted and how much effort would be made to decontaminate.10 Decontamination would be difficult enough, however, so that the inner contour on Figure VII indicates a potential "no-man's land" -- a region in which people would not be allowed to live or work except for limited periods of time for a 100 years.
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-10 Over the years, some of the radiat#on would spread out still further due to wind blowing around particles which had been eroded and resuspended. This
. spreading, although representing a relatively small amount of the rekeased radioactivity, would be a source of continual worry for residents of other areas.
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Alternatives to Indian Point Ideally, before making decisions, political leaders should be infomed about the side effects of each energy option. My purpose here today is to help in that process.
I have been concentrating today on certain. side effects' of nuclear power, but I do not want to leave the impression that there are no problems with other enenJy options.
One should not lose sight of the ' fact that fossil fuel electricity sources (which might be increased ifIndian Point were shut down) have equally as shocking health effect's associated with them.
It is not generally known, but still true, that air pollution from oil-and coal-burning plants kills people.
Estimates range from one to 100 deaths to the public per average 1000 megawatt plant per year.U That means 30 to 3000 deaths over 30 years from an average plant.
There is probably no " safe" level of sulphur emissions, just as there is no safe level of radioisotope emissions.
Thus, one must not leap to the conclusion that all alternatives to Indian Point are preferable.
Reactivating oil or coal plants in flew York City could be construed as conderming 100's of older residents each year to premature deaths.
The decision about which opt. ion is preferable is a political decision involving values, not a technical decision.
Rational people may prefer to tolerate a certain number of air pollution deaths each year to prevent the phance of a single catastrophy which would paralyze and shock society.
On the
.other hand, other rational people could decide that the risk of catastrophy was preferable to actual deaths occurr,ing each year.
In any case, there are alternatives to Indian Point which do not involve dramatic increases in air pollution, and it is to those alternative we should i
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turn.
For instance, the burning of natural gas does not appear to produce significant amounts of lethal air pollution.
Nor would air pollution be increased by a strategywhich reduced electricity consumption to such an extent that Indian Point was no longer needed.
(Such a strategy might involve substituting more efficient appliances and motors for our present wasteful stock.)
However, each alternative has a price, both economic and social. Without detailed study it is not possible to predict just how desirable each alternative (or mix of alternatives) might be in this specific region.
Consequently, I recomend that technical studies be made to investigate alternatives to Indian point. Two studies should be carried out, one by the utilities and one by independent, technically competent people who are critical or skeptical of nuclear. power.
This second study would be independent of, but work with, government agencies.
An independent group, biased away from nuclear power, would be most motivated to find acc'eptable alternatives.
Several consult-ing fims with suitable biases exist around the country (I know of at least one in New York State), one of which could be hired by the State or the City to make the case for a'lternatives.
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The utility study should lay out the case against the alternatives.
When completed, the two reports. can be debated and the public given a rational frame-work for choosing between the various options.
I have, myself, been involved in such parallel competitive studies (about nuclear risks), once in Sweden and once in West Germany, and iecomend this approach.
Obviously, such studies costs money.
I estimate $100,000 would be necessary for the non-utility study.
Perhaps there is some way that the utilities could be 4
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assessed the fee; perhaps they would volunteer it to demonstrate their good faith.
If not, I think.that the City or State should give serious attention to securing the necessary funding.
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partial evacuation might still be necessary after the passage of the plume. The faster that people coul'd be rcmoved from contaminated ground, the smaller would be the number of accumulated cancers and other health r.ffects.
But where would such people go? Where would they be housed and how would they be fed? How would looting be controlled? These ouestions should be considered now when there is time to think matters through.
An emergency plan for New York City should not be limited to planning for evacuations.
It should include distribution of thyroid-blocking medicine and inforination about sheltering.
Local radio stations could be used to relay the instructions which might be needed.
It is not easy to design an energency plan that, remaining unused for years, would work on connand. The only method in which I place any confidence is that used in Waterford, Conn, for the imediate surroundings of the Millstone Complex.
Due to the initiative of the local Fire Marshall, Douglass Peabody, a plan has been developed in which each detail has been thought through in military detail.
A key element in the plan is the constant notification of the police of even minor accidents at the plant -- even broken legs.
In this way, communication-procedures are constantly checked.
Such connunication procedures could be established between Indian Point and both the New York City police and the Bureau of Radiation Protection.
I recomend that the City Council and the Nayor set up a task force to
- develoo the outlines of a New York City emergency plan for reactor a;cidents.
Because of the general lack of knowledge about these. accidents, the task fo'rce would have to include expe'rts from outside city government to work with the relevant. governmental agencies.
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Iodine Blocking Potassium iodide pills taken before breathing radioactive iodine in the plume would reduce thyroid doses by ten to one hundred-times, due to the blocking of radioactive iodine uptake by the already saturated thyroid.
Obviously', the pills could not in practice be delivered to everyone, even with a carefully planned distribution system. Also, the pills do not block radiation doses to other organs. Therefore, iodide blocking is not a panacea for reactor accide,nts.
Nevertheless, potassium iodide is cheap (it is the form of iodine added to iodized salt), and could significantly reduce the number of p'eople affected by an accident.
(As can be seen from Tables Va and VIa, thyroid nodule cases are likely to be the most prevalent health after-effect in the absence of thyroid blocking.)
Potassium iodide was approved for this purpose by the FDA in December of 1978.
Let me quote from the notice in the Federal Register (complete copy attached).
"The Comissioner concludes that potassium iodide is safe and effective for use as a thyroid-blocking agent in a radiation emergency under certain specified conditions of use because it has been widely used for many years, in large doses, and on a long-term basis with an incidence of side effects and toxicities, in general, proportional directly to dose and duration of therapy. The risks from short-term use of relatively low doses of potassium iodide in a radiation emergency are outweighed by the risks involved from exposure to radiciodine.
Almost complete (greater than g0 percent) blocking of peak radioactive iodine uptake by the thyroid gland can be obtained by the oral administration of 100 milligrams (mg) of iodide (130 mg of potassi,um iodide) just before or at the time of exposure.
A smaller dose (65 mg of potassium iodide) can be used in infants under 1 year of age.
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. daily dose is required to maintain the blocked state.
The use of a blocking agent is not expected to exceed about 10 days."
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. At the time of the Three Mile Island accident, potassium iodide was not yet available for mass distribution in the proper dosages.
The FDA therefore ordered large-scal'e production on an emergency basis and within a few days had flown enough into Harrisburg for more than a half a million people.
But this would have been too late if the containment building at Three Mile Island had failed early in the course of the accident.
It makes sense to stockpile the medicine directly in the city -- perhaps at every police station.
Stockpiling of potassium iodide is particularly important in crowded urban environments where rapid evacuation is not a realistic alternative.
Note that, in California, the Nuclear Power Plant Emergency Response Panel established by Governor Brown after the Three Mile Island incident has already recommended procurement and deployment of this medicine to local emergency response agencies.13 I hope that New York City and New York State will take the initiative in this matter in the East.
Conclusions The city government has the opportunity to significantly improve safety for its residents.
Commissioning a study on Indian Point alternatives, creating a task force on emergency planning, and investigating the stockpiling of iodide pills, would provide the kind of leadership in the nuclear safety area that is sorely needed.--c.
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-18 I
e Footnotes and References I$
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1.
Reviews of Hodern Physics, 47_, S1 (1975).
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The d'esign goal for the probability of complete failure of reactor safety system'j c,
was less than one-in-a-million per reactor year of operation.
This goal
[
S was assumed to have been achieved until 1974 when the authors of 'the U.S.
f V
Reactor ' Safety Study (WASH-1400, the so-called Rasmussen Report) estimated E
6 a meltdoh probability some 50 times higher (one-in-20,000 reactor years)
P 11 based on a deta'iled analysis of certain accident modes.
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The Three Mile Island accident indicated that even the Reactor Safety Study (RSS) was optimistic:- by at least a factor of 10.
The least serious N
vi
{N accident considered in the RSS (PWR9), with a lower release into the con-tainment than actually happened at Three Mile Island, was assigned a ti
$i probability on one-in-4000 reactor years.
Yet, the Three Mile Island
.w lh accident occurred after a total experience of only about 400 reactor years ld (cummulative total).
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it 3.
Reasons why people would tend to underestinte failure probabilities of kO ccmplex systens such.as nuclear reactors were discussed in the psychological f
x literature before Brown's Ferry and Three Mile Island.
See A. Tversky and pl.
D. Kahneman, Science 185, p.1129 (1974).
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4.
One reactor-year is taken here to mean one year's operation of a 1000 Mw(e) g j;g 2N plant.
400 Reactor-years is equivalent to 80 large reactors operating for v.s 5 years, 40 reactors operating for 10 years,. etc.
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5.
It is true that the amount of radioactivity which seeps into buildings is reduced.
However, the material which does get in is trapped and stays inside for a time longer than the plume passage time.
The longer breathing time inside compensates for the reduced penetration.
6.
To obtain sufficiently high doses one of the following events must occur:
1) heavy rain or 2) release on a clear night with low wind speed and high fallout rate, or 3) sudden drop in wind speed or increase in tur-bulance while the plume passed over the city.
I have discussed some of these possibilities in prev fous testimony given before the New York City Board of Health.
(Ref. 6).
Based on my experience with other sites I would estimate a one-in-ten chance that one of these events would occur at the time of the accident.
7.
Jan Beyea, " Consequences of a Catastrophic Reactor Accident", Statement to the New York City Board of Health, August 12, 1976.
This referebce accident differs somewhat from that chosen in the sec 8.
Brookhaven report (WASH-740 update) often referred to by anti-nuclear activists.
The Brookhaven report assumed a 50% release of everythina in the core, whereas WASH-1400, based on later experimental data, assumed a higher fraction for the most volatile isotopes, but a much lower fraction for non-volatiles.
This leads to a 2 times lower short-tem dose and somewhat shorter distance range of early lethalities for the accident con-sidered here.
There should not b'e much difference in the long-tem dose.
e s.
Nevertheless, the Brookhaven report projected, in the worst case, a land contamination figure five times higher than I would project.
I do not know yet whether this is due to the different release fractions ~ assumed or due to different land contamination criteria.
9.
A 10 rem in 30 year threshold level has been used.
This is equivalent to the criteria used in WASH-1400 for rural land, but not the 25 rem in 30 year threshold assumed for urban land.
However, 25 rem in 30 years appears to be higher than that recomended by the International Comission on Rad ~iation Protection, (See WASH-1400 App. VI, Ch 11.)
A 10 rem dose implies a fatal cancer risk of a few tenths of a percent, assuming four hundred cancer deaths per million person-rem figure.
This dose coefficient is equivalent to assuming a " relative risk" model rather than an " absolute risk" model which was in favor in the past.
Note that the majority statement in the draft report of the new National Academy of Science report o.n ionizing radiation makes us of the relative risk model.
10.
The micron-sized aerosol particles would attach themselves strongly to surfaces.
To decontaminate, it might be possible to replace window glass, and sandblast outside building surfaces.
Inside surfaces would be less heavily contaminated, but possibly more difficult to scrape clean.
11.
These estimates are made by correlating death rates with pollutant levels.
The results are higher than would be expected frca known effects of sulphur compounds, suggesting synergistic effects with other pollutants.
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21-Trace Contaminants from Coal, S. Torrey, Editor, Noyes Data Cor, ' ration, Park Ridge, New Jersey,1978.
Note that there are long-term problems associated with burning fossil fuels, just as there are long-term problems with nuclear wastes.
Increased CO in the atmosphere may well lead to dangerous overheating of the earth 2
in the next 50 years.
12.
" Post-Accident Filtration as a means of Improving Containment Effective-ness", B. Gossett et al, Los Angeles, University of California UCLA-ENG-7775 (1977).
- 13. Memorandum to Governor Brown from Russell Schweickart, Assistant for Science and Technology, May 25, 1979.
14.
Considerable controversy exists about the effects of low level radiation.
At the present time, I see no alternative to stating a range of health effects which includes most predictions, i.e., based on a coefficient range of 50 to 500 cancers per million person-rem to the whole body.
For comparison, note that th'e range given in the majority statement of the new National Academy of Science BEIR II (draft) report is 70 to 353 excess fatal cancers per million persons exposed per rem for single exposure, and 68 to 293 pe'r million per rem for continuous exposure.
These numbers, however, are stated to be uncertain, depending upon the age mix of the exposed population, as well as other factors.
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Table I Distribution of Weather Conditions and Wind Direction (taken 'from the Preliminary Safety Analysis Report for Indian Point 3.)
Frequency of Weather Classes Inversions ( E'& F) 41%
, Neutral (D) 31 %
Unstable '(A, B, C) 28%
Wind Rose Data (for the 300 ft, tower) suggest the following relevent percentages:
Percentageoftimethatgind Percentage of time that wind direction lies in the 45 direction lies in the 900 sector including New York City sector containing the New York metropolitan area f
with Inversion (F & E)
Conditions 6%
11%
with Neutral Conditions (D) 10%
20%
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with Conditions (A, B., C) 6,.
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Unstable i:
7 3!
Total 22%
34%
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TABLEII i
PROBABILITYESTIM^T5S#UR"kCdiD5NTS AT INDIAN POINT OV5R 30'VEAR [IF5 TIME TYPE OF ACCIDENT PRosABILITY-
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1)
ONEWHICHSHOULDTRIGGERbMERGENCY RREPARATIONS IN [lEW YORK lTY, BUT WITHOUT A LARGE RELEASE OF RADIO-ACTIVITY ACTUALLY OCCURRING lgA) 2)
ONE WHICH LEADS TO A LARGE RELEASE OF RADIOACTIVITY WITH THE WIND NOT 1.5%(SUBggggE T
BLOWING TOWARDS THE CITY 3)
ONE WHICH LEADS TO A LARGE RELEASE OF RADIOACTIVITY WITH THE WIND BLOWING TOWARDS THE CITY CAUSING )
,3g (SU CANCER AND OTHER HEALTH EFFECTS C EC 4)
M CAUSES EARLY DEATHS IN
.03% (SUBJECTIV ESTIMATE.
A)
HALF TH? FREQUESCYh*dICH h0VLD BE OBTAINED FRCM THE OCCURANC OF THE 3ROWN S cERRY FIRE AND THE THREE flILE ISLAND ACCIDENT.
(SEE TEXT).
B) 8SSUMINGTHATl-IN-10ACCIDENTSLIKETHEBROWN'SPERRYFIREAND IHREE MILE ISLAND LEADS TO A LARGE RELEASE, C)
BASED ON A 1-IN-5 CHANCE OF TH5 WIND BLOWING IN $UCH A WAY THAT A SIGNIFICANT FRACTION OF THE PLUME PASSES OVER LITY TERRITORY.
DI SEE FOOTNOTE 6.
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.5; TIME FRAME OF RECEIVED DOSES
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IMMEDIATE DELAYED
{
1)
FROM PASSING CLOUD.
1)
FROM INHALED RADIOACTIVITY
)g STORED IN THE BODY.
2)
WHILEREMAfNINGINCONTAMINATED 2)
FROM GROUND CONTAMINATED Ih GROUND BEFORE EVACUATION.
TO LEVELS TOO LOW TO Pi
~'
JUSTIFY EVACUATION.
ij mi mp
. f'
}i di TABLE IV
_E kn TIME FRAME OF HEALTH EFFECTS hj
@}
- (
IMMEDIATE DELAYED y,
?!
SICKNESS AND DEATH FROM DOSES.
CANCER; DISEASES, DEVELOPMENTAL S OF THE ORDER OF.00 S.0F REMS.
AND GENETIC BIRTH DEFECTS 25i OCCURRING WITH DECREASING BUT hjj NONVANISHING PROBABILITIES WITH wi DECREASING DOSES.
p w
Af 4*
n.Y
TABLE VA APPROXIMATE DOSES IN REM RECEIVED 35 MILES AWAY FROM INDIAN POINT FOLLOWING A " MODERATE" ACCIDENT )
A DOSES TO DOSE TO HYROID GLAND WHOLE BODY ADutTS~
CHILD N
UNDER FROM INHALA ION AND B
CLOUDSHINE
. h_US 1 DAY'S GROUND C
EXPOSURE
.5 REM PLuS 7 DAY'S GROUND C
EXPOSURE
.9 REM PLuS 2M0g1TH'SGROUND C
EXPOSURE.
1.6 REM A) 5% IODINE, 60%_ XENON AND KRYFTON.
"D" WEATHER STABILITY, 10 MPH WIND,.01 M/SEC DEPOSITION VELOCITY, 25 METER PLUME RISE, WASH-1400 DISPERSION COEFFICIENTS, GAUSSIAN PLUME MODEL.
B)
CLOUD SHIELDING FACTOR = 0.6.
c)
GROUND SHIELDING FACTOR DUE T^ BUILDINGS = 0,2.
THESE DOSES ARE UNCERTAIN TO AT LEAST A FACTOR OF FIVE UP OR DOWN DUE TO UNCERTAINTIES IN THE " STICKINESS" 0F THE AEROSOL PARTICLES CARRYING THE RADIOACTIVITY.
bR HEALTH ffFECTS AT 35 MILES FOLLOWI?E A I'ODERATE AcCIDarr
,u 0
(Ib IGDIDE BLOCK!fG ASSUiED)
PERMILLIONPOPULATIONEXPOSED DE!.AYED CAtCER DEATHS )
B FRa4.2 REM INMLATION NO 'CLCUD SHINE 10TO100 FRGi 1.4 REM GRoutO DOSE 70TO700 CASES OF TWROID tDDULES,D)
C FRQ4 300 RB4 TO CHILDREN 12,C00TO60,033 FROM60REMTOADdLTS
.,3,00) TO 40,020 IbN-FATAL TWROID CNCERS,E)
C CHILD 633 TO 303]
ADULT 80] TO 5,0]O FATAL TWROID CAtCERS,F)
C CHILD 22TO.120 ADULT
- 10)TO700 A)
IF THE WIND'WERE BLOWItB TOMRDS MANMTTAN, THE EXPOSED FOPULATION IN liEW YORK CHY MIGHT NUMBER 3 MILLION, WHEREAS IF THE WI?O WERE BLOWItB TOWARDS STATEN ISLAtO, A MUCH EPALLER tGBER OF CITY RESIDETTS VDULD BE ItNOLVED.
B)
EASED ON 50 TO 500 DEATHS PER MILLION PERSON-REM.
SEE FOOTt TE 14.
C IHYROID EGSE/EFFECT COEFFICIBUS TAKEN FRCM R=v f>'on PHYSICS, 47, S1 (1975).
D)
EASED ON A COEFFICIBir 0= 275-2500 CASES pER MILLION TWROID REi NO TH ASSuiFTION TMT 15 PERCEffT 0.: THE POPU' ATION ARE CHILDREN LESS TIRN 10 YEARS OF AGE.
ItCIDE?CE OF NODULES FOR ADULTS TAKEl AS 3/2 THAT OF CHILDREN, REM FOR REM, BASED ON 1978 mRSmn =SE DATA.
E) EASED ON A COEF?ICIE?E OF 12-75 CnCE !S PER MILLION THYROID-RE4 F) EASED ON AN ASSUd.ED 4% FDRTALITY FOR CHILDREN,15% FOR AW_TS.
g IABLE VIA APPROXIt' ATE DOSEC IN REM RECEIVED AT 35 MILES FRGi INDIAN POltrr FOLLOWItB A RB2 ACCIDEffT.A)
DOSE TO DOSE TO ID G m ADULTS CHILDREN wmtg 30gy utOER10 FRG4 INMLATION Ato CLOUD SHINE )
4 REM 10]O 5WD B
PLuS 1 IMY'S GROUND EXPOSURE )
12 C
PLUS7 DAY'SEXPOSURE) 32 C
PLUS 8 WEEK'S EXPOSURE 66 A)
"Pa2" ACCIDEffi RELEASE FRACTIONS TAKEN FRCr4 MSH-1403.
10 MPH WIta, D STABILITY,.01 WSEC DEPOSITION VEL 6 CITY,150 METER EFFECTIVE RELEASE HEIGHr, WASH-1400 DISPERSION COEFFICIENTS, GAUSSIAN PLlf4E t0 DEL.
B) CLOUD SHIELDItB FACTOR = 0.6.
C)
GROUND SHIM nit'E FACTOR = 0.2.'
(THESEDDSESAREUNCERTAINTOATLEASTA FACTOR OF 5 DUE TO UNCERTAltfrIES IN THE " STICKINESS" 0F THE AEROSOL PARTICLES CARRYItG RADI0 ACTIVITY.)
e
,y
-w
TAEu: VIB f4uoR HEALTH EFFECTS FROi INmLATION, CLOUD SHINE, AND 1 DAY'S EXPOSURE TO CONTA'iItMTED GROUND AT 35 MILES FOLLOWItG A P<R2 AC p
(Ib IODIDE BLOCKItG ASSU4ED)
}.)
t @ M [f)
DELAYED CANCER DEATHS )
603 TO 6033 PER MILLION PEOPLE EXPOSE B
THYROIDEFFECTS)
VIRTUALLY AU. EXPOSED CHILDREN'S AtO A D
LAPGE FRACTION OF ADULTS' THYROIDS FOULD DEVELOP ?ODULES. A LARGE FRACTION OF W YROID t0DULES FOULD RE0JIRE SURGICAL TREATMEtE Ato LIFETIME MEDICATION THEREAPTl 9
DEVELOR4EtKAL DEFECTS MICROCEPMLY (SSLL HEADS)B) 107. OF EXPOSED F0ETUSES )
E GetETIC DEFECTS PERSONSWITHIDEIRIFIABLEDai!NEtR GENETIC DEFECTS OVER AN AVERAGE OF FIVE GENERATIONS )
3C0 TO 30]O PER MILLION PEOPLE EXPOSd' B
A) SEE TABLE.VB FOR DOSE COEFFICIEhTS USED. THE ONE MY GROUND EXPOSURE AN OPTIMISTIC ESTIt%TE FOR AVERAGE EVACUATION TIME.
B)
FRCN 12 REM ExeoStas.
C)
IF THE wit 0 WERE BLOWItG TOWARDS I4Vl!%TTAN, THE EXPOSED POPULATION MIGHT tM4SE7 3 MILLION, WrEREAS IF TE WIND WERE ELOWItB TCWARDS STATD1 ISLAfC A MUCH S4ALLt NU43ER OF PEOPLE YOULD BE ItNOLVED.
D) 10I REM TO A6)LT, 50I TO CHILDREN U:OER 10.
NOTE TMT BECAUSE OF THE LARGE NUi3ER Ci THYROIDS WHICH FDLLD MVE TO BE REM 3VED SURGICALLYs THE INCIDENCE OF CANCER YOULD t0T BE TMT HIGH.
E) hE38--140], TABLE VI F-9.
F) ~ EASED CN IABLE M/III o= Revs Fbn Puysms, h7. Si 0479.
~ TABLEVIA APPR0xituTE DOSES IN REM RECEIVED AT 35 MILES FRCri ItOIAN Porttr FOLLOWItG A PiB2 AcCIDErrr,^)
DOSETO DOSETO OID b ADULTS CHILEREN WH3LE BODY UtOER 10 FRCri INH \\LATION AND CLOUD SHINE )
4 REM 1000 5@
B PLUS 1 DAY'S GROUND EXPOSURE )
12 C
PLUS7 DAY'SEXPOSURE}
32 C
PLUS 8 WEEK'S EXFOSURE )
gg C
A)
"PWR2" ACCIDENT RELEASE FRACTIONS TAKEN FRCri WASH-1403, 10 MPH Wire, D STABILITY,,01 WSEC DEPOSITION VEL 6 CITY,150 Mettx EFFECTIVE RELEASE HEIGHT, h43H-1400 DISPERSION COEFFICIENTS, GAUSSIAN PLLME 10 DEL.
B) CLOUDSHIELDINGFACTOR=0.6.
C) GRCUND SHIELDItG FACT 0a = 0,2.
(THESEDOSESAREUNCERTAINTOATLEASTA FACTOR OF 5 DUE TO UNCERTAltEIES IN THE " STICKINESS" 0F THE AEROSOL
~
' PARTICLES CARRYIfG RADIOACTIVITY.)
e
28 h
TAsLE VIB 4s liuCR HEAtm EFFECTS FRCM INMLATION, CLOUD SHINE, no 1 DAY'S
' 04 EXPOSURE To C0tEAMItaTED GROU?O AT 35 MILES FOLLOWItB A PS2 AcCIDan.Aif Gb IODIDE BLOCKIfE ASSlf4ED) y[>
j,k DELAYED 6WCER DEATHS )
600 TO 6 E PER MILLION PEOPLE EXPOSED
}h B
S.
THYROIDEFFECTS)
VIRTUALLY ALL EXPOSED CHILDREN'S A?O A N'
D w
LARGE FRACTION OF ADULTS' THYROIDS YOULD
!y DEVELO? tODULES. A LARGE FRACTION OF
.rt.
TINROID TODULES VCO.D REQUIRE SURGICAL v
TREATMBE AND LIFETIME M a
DEVELO.HEtEAL DEFECTS T
MICROCEPFMLY (SMLL HEADS)B) l@ OF EXPOSED F0ETUSES )
,ff E
b, ej.
GaerIC DEFECTS k,f PERSONS WITH IDBEIFIABLE DCMINENT Id W
GENETIC DEFECTS OVER AN AVERA3E OF lt FIVE GENERATIONS )
E TO 30 1 PER MILLION PEOPLE EXPOSED,F) f B
C 6i$
v A) SEE IABLE.VB FCR DOSE COEFFICIENTS USED.
THE ONE DAY GROUtB EXPOSURE REPRESE AN OFTIMISTIC ESTIt%TE FOR AVERAGE EVACUATION TIME.
IE w
A B) FRai 12 RB4 EXPOSURE.
f in
,C)
IF THE WIND WERE ELOWItG TOWARDS MANPATTAN, THE EXFOSED P0FU!ATION MIGHT NLMBER f 3 MILLION, V&EREAS IF TFE WIto WERE BLOWING TOWARDS STATEN ISLMO A MLEH S4 ALLER %
NtNBER C PEOPLE YOULD BE It#0LVED.
D If!
e:
D) 10I REM TO ADULT, 50I TO CHILIREN UNDER 10.
tbTE TE%T BECAUSE OF THE LARGE
+E h
NLMSER Cf THYROIDS YMICH VDULD 1%VE TO BE REMOVED SURGICALLY, THE INCIDENCE
{-g 0F CANCER VOLLD POT BE THAT HIGH.
i{
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.b LONG-TERM LAND CONTAMINATION CONTOURS
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....q.
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J..N OTIC 15 53798,*.*
e
- 1rene effects from exposure to ndI-blocking purpcses under certain emer-
[4110-CS-M]..
1 ation in the event that rs iloactivity is sency conditions.
released ints the environment. These The report dscusses s*ockp11h2g thy-DEPARTMENT OF HEA1.TH, EDUCATIOH, AND WEI. FARE plans are to belude the prophylacite ro!d blectins asents rt approprute
. use of drugs that would reduce the ra.
outleta for case of distributton in the
^'
diauon dose to specL!1: organs due to even'. their use is necessary in g n,n.
- Fe J oe=J Dws M :ab eh**
the sudden releue into the e=viron. s.tlen emergency. The. report con-(Deet No.iaD-C;431 ment of large quantitles of radicactiv. eludes, however, that the detalls of POTAsstum toD4DI As A TWtots-4 LOC'.M3 ity that m!ght include several nd!oac. stockp1Hng. if this method is to be ACENT t&A aAmAT1CM f#t20lHgY Live botopes cf lodine.
Used, and of d!stributton wou d be de-termir ed best at the State sad local hCaomvD levels.
t.S.:t.,54 ht...tH.-tw Apr s
- " *
- d A* 9 D ~#
The SA notice of December 24 A m,,rsts
..- 1975, concluded that there is an ex-
- AGENCYt Fcod and Drug Metn. ceedingly low probability that b ei.
The Commiss!:ner of-Focd and tion.
r dents win occur involving either the Drugs has analyzed the NCRP report use of radioactive materials in fixed and the ava!Jable scientt!!: I!!crature nuclear fac!Utles or the trar.sportation abou* the poss!ble prophylactic use of -
SUhDdARYt The Food and Drug Ad.
cf those materials. Becauss of the pos. drugs to reduce the radiation dee4 to -
rninistration (FDA) requesta submis-s!ble increce in number of. nudeu the thyrold gland in a ndlation e=er.
sions of new drug app 11:st'ans (NDNs) power phnts, however. s,everal Federal gency. Although a varfety of chemhl for pottsstum lodde in oral dosage.agendes ne identLfying those pos.st-substances can block the accumuhtjon,
forms for use as a thyrold. blocking bilities, however remote, that could i of radolodine 6 the thyroid gland.
todide in the form of potassium 1:41de agent in a rsdiation en2ergency. The adversely affect the publje. should s.n Cpproval of oral dosage forms of pot.as-ineldent occur. One possibility is the appears to be mest suitable for this
. slum todide as a thyrold blocking sudden release of lure quantitles of purpose. A number of facton.were considered in choosing lodide (and spe-wculd be one step in meeting the re. ' radionucUdes, which might include a, agent for use in a radiation emergen:7 cifically potasslum lod!de) over other nun 2ber of isotopes of rad!oledine. into blockbg agents such as propylthjoura.
sponnbiljtles, of the Department of the environment. When radiolodtnes cH. methimuole, perchlorate, thlo-H ealth.
Ecluestion, and. W elf u e are inh *3ed or ingested, they rapidly (DEEW) to State and local govern
- accumulate in the thyroid gland and cyanate, or todate, nese f actors in.
cluded the degree of the bics:t!ng menta for ridiological emergercy re-
- are metabol!:ed into organi iodine acned the mMy on onset of the sponse planrdnr. The agency encour-compounds. These co:spounds could blocking effec;. the duration of the ages interested persons to sub=lt in the thyroid gland long MDNs in the interest of the pubuc. reside blocking effect, and the safety of the enough to allow for local radiation blockbg agent. Although lodide neta safety. The agency is also announcing darnage. resulting in thyroiditis. hy-on the thyroid gland in severaJ ways.
the av2flihllity of labeling guide 1!nes pothyroidism, or thyrold neoplasia, lu use in tMs inst 2me is pn=ady for potar. stuns lodide for such use..
with eltber benign or mal!gnant char.
18 "D I
L*
ADDRESS: Sub=Jt new drug appUca. seteristics. Therefore. {t is cons!de:ed (#*dI *j
, gy g
g, Lions to the Food sad Drug AnmHk.
in the public interest that State and huvely abolish entry of radiolodina effective c2 ensures to prevent er cur except for sm111 amounts that m!ghi local authorities be prepared to take tration. Division of Metabollsm and Endocrine
- Drug Frodu:ts (EFD-130).
cater the gland by diffusica gg, g"*
- Almost, Rm.14304, 5600 Fishers Lane, Rock. tail mutedly the accumulation of ra-3,,,
ggg g
djoicdines by the thyroid gland, blxting of peak radiomettve iodine 1rille. MD 20857,. Comn2ents concerning the labeling guideline and requests for should su:h an incident occur. These uptake by the thyroid gland can be ob-copies of the guideline should be sent ' measures may include the use of r.
tained by the oral administration of to the Hearing Clerk (HTA-305). Food thyrold blocking agent.
100 mf1!!rra:ns (mg) of lodide (130 m~*
and Drug Administntion, Rns. 4-d5,
. An ad hoc committee to the National of potassium ledde) just before or at 5600 Fishers Lane, Rockville,. MD Counc!! on Radiation Protection and the tLme of exposure. A smaller dose 20&57. -
. :.. Measurements (NCn?), *.rhich includ. (55 mg of potassium lodide) can be ed FDA representatives as comultants. used in infants under 1 year of age. A
.FOR FITR*mER - BTORMATION-an2dled the fessMuty of usbg certain daily dose is required to maintain the CCh* TACT **
n.?
dn:g products as thyroid blockbr blocked state. The use of s, blocking Jr.y ' Bur.au of agents to reduce rad!ation dose to the agent is not expected to exceed about Edwin V.
- Dutra, Drugs (HFD-30), Food and Drug Ad-thyroid gland. The NCRP, located in 10 days.
rainistration, D partment of Health. Dethesda, Maryland. is a nonprofit Experiments designed to study the Education, and Welf are, 5600 Fish-corporation chartered by Congrer.s in rapidity of onset of blocking hava ers Lane, Rockville, MD 20857, 301-1954 to collect, analpe develop, and shown that at a 100.mg dose of todide',
443-6490.
dissem!nate information and r*com*
the onset of blocking is readly demon-SUPPLENENTARY D70RMATION: mendations about radation protec-strated 30 minutes af ter oral adminis.
By FrorxA. Rects rn notice of Dacem.
tien. The NCEP is made up cf 55 sci-tration. The decay of the blocking ber 24,1975 (40 FR 59434). the Gener, entLfic cocanittees, co=pesed of ex*
ef fe:t af ter cessation of ledide adn.in-cl Services Adrninistradon (GSA) out-perts having detailed knowledge and istration is relatively slow. so that a lined the respomtbilities cf several conspetence in the part!:ular area o! da!!y dose of 100 mg of lodide (130 mg Federal agencies conceming certain the commJtteels interest. An NCRP of potar. slum lodide) appears to main-emergency response plannmg guld-report published August 1,
1977 tain e!!ective blxting. To have the ance that the agen:ies should provide (NCRP Report No. 55, "Protecuan of greatest effect in decreastnr the accu-to State and local authorities. The De-the Thyroid Gland in the Event cf Re-mulation of r2delodine in the thyroid partment of Health. Education, and lease of Radlotedtne") d!seusses the gland, the thyroid blo-ting agent Welf are (DITW) is responsible for 2.5
- aafety and efficacy of thyroid-blocking shodd be administered immecie te!y sisung State and local authorities in agents and recommends that potas-befo e or af ter init!al exposure. A sub-develop!ng plans for preventing.ad-sluts !cdid; be considered for thyroid-stanual htnefit (e.g a block cf 5? per-
- RIM 1At itC13TU, C4. e3, >>. 24-M:nAT, gfCIMaI2 13, IW3
/
M~
No 1cis p3m f
t.bla fer CrrC cale do-s not tff ct the
) is i.ttabable, hoverer, when the Coxc:.t stons king agent Ls first stven within 3 Th2 Commissiontr concludes the.t present s'.ams m.s a nedpdon d.mg fnW mi e drug product
, houn af ter acute exposure. If a p,,mium Imide ti safe and effective on is exposed to ndo!xiine when for use as a thyro!d blockbg agent b "" *#' ages.
. '*#3 O# "I O
j higher dos rnstssces do not permit the im*
a radiation emersen:y under certain g
The importance to the puhu: of late aN+tntion of pot. ass!us2. specified condittons of use becatae it ready and convenlent acceu to this fe. the initial um!-tstestion vill has been Mdely used for many years, product and,the un11kelihood that 1t f somt li=.!!ed benefit even as lonJ in large doses, and on a long term will be needed re. force the Com_s-2 hours af ter exposure.
basts with an L :1dence of side effects afecer's belief that potaulu= todide as thou2h mos* cf the rstoicd!ne and tex 1:ltles. In general. proportional ts not taken up by the thyroid directly to deee and duration of ther-a thyrold-block.nr uent b a ndiation emergency should be considered suit.
d b excreted in the urine Mthin apy.The rtst.s fro = the short-term use ours. the radiciodine that is taken of relat!vely low doses of potasslum
- DI' I #. OTC use. The Cornmissioner s '.s bebeves that spec.al labeling di.
2y. sad accumulated in, the thy.
lodide in s. radiation emergency are g!r.nd =.ay be " leaked" baqk bto outwelzhed by the rbks bvolved from rected to the patient r=ust accompany the 'wdiate container of these OTC l
general cirt-ulation system a.s a exper.ure to rad!o!cdine. However, the equence of intrs*MToldal metabo. Comm%2!aner does not believe that prepanMons to ensure they are ud g
. Thus. there is Ipou!bility that ptassium lodfde ha.s been tued to safe y e
y.
A e]d and rec *~ ~ula%~ g radiolo-such an extent or for a period of t.=e da*"a'y"be taken up by the thyroid
- h for=stl n to be included on the coo.
t bee speciflad conditb"ns tob:lusion tha* the d.-ug b taber label !! space permits, and if ttnde-In
- (fr~ the cir:ula., ry system) pgeneraHy neorni ed as safe and effec. the accompanying labelbg is on fue
- though there are no radioicd es tive. Accordingly, it b regud-d a.s a with the Hearing Clerk. FDA. The g
sining in the enviren=ent. 4o pre-new drug regtdring s.n approved new gn!deline rets forth speelfi: language xibe by the thyroid gla-d from ketbg. Thus, the Comm% loner vu.1 agen:7 I.
or curtail the accumu.lation of ra.
drug app 11:2tton as a condtion of roar, that would be
- a. ceptable to the tarce. In ]uding chode expo-s.: cept new drug app 1! cations Inetting
'nie guld:11ne ls entitled "Guldeline
, a daily dese of a thyrold.blockbg the requjre=ents of (314.1 C1 CPR Labelby for Po'asslun Iodide for Ure'
.t is necmey for a period of time 314.1). Because of the pubU 17 ava!.lg.
as a Thyroid Bicding Agent in a Ra-
- exposure. The duntion of time ble safety and e!fina.cy data docu=ent.
dation Emergency."
c blocking agent would be n-. Ing the d. rug's tue, the r.afety sad eff!.
Theenon responsible ic: maintain.
g ed ts not expected to cr:eed about ca:y regulrements of I 314.1 may be irg the.ru!deline labellnz ls JoAnne C.
l nys. A mbimum of 3 to 7 days of met by citing tt.e pubitshed Ete sture U rrone. Food and Drug Ad ',istra-administration b a.nt!cipated in the L!st of Material Consulted t!cn. Division of Metabolism and Ea-d on the biological events d a-(below) documenting its ttse. Tne d xrine Dru g Produ:ts E.:TA-13 0 ).
L ed above s.nd the eff ective half Co=minioner aduses that it b unnec-Recm 14M4. 5600 Fuhers Lane. Ro:1-g mL es.sary to sub=!t (1) copies and re Ville. MD 20357, 301-443-35:0. Copies tantum lodide 'has been used prints of the data cited in the List of of the guideline ne avaDable frum the ly for many years b the tregt. Material Consulted in this document. Hearing Ciert (address above). -
t of bronch!*.! s.sthms and other and C) ccpies and reprints contained g"
,g "
sons y d:sorders. DAUy oral dom in the Journals listed b } 310.9 C1 otassiu it,d!de T'JM" 3 from 300 CFR 310.9). Both the safety and effi.
- 1. Adu: s. C. A. and J. A. Bonnen. " Admin.
cacy data upon wblch the Commh.
Is+auen of stable I:dide u a ? dea..s of Re-
.00 mg have been given to asthma-r,foner bases the above conclusions and cuems Thyroid 1.tncation reset:ns fro:s over long periods of time. Dauy W '" ' I R*63^#"
I * ;^* ~ NI" NCRP Rep ort No. 55[he Event of Re-
" Protection of the Thyroid Gl.and in. 3.re On fUe for
@'m*u'_D **
- 2-doses of potanium lodde of 100 n E and M. Euenbu, Reductbn
): greater have b*en administered les.se Of Radleto ne.
c! Thr:old Irraintion from 131 I by Pottu t
a.
) ugh prepara!!ons to children Al-public b.sptClion in the off1Ce of the skm ledde/* /ownc! of tar A nc-i:2n Mede.
- gh a vuiety of advene reactions Hearing Clerk. Food sad Drug Ad.~in-e:2 Auxsetten. 2%:103t-10to. luT.
been reported in ecnnection ritis btration. The Commissioner invites
- 3. Ramsden. D F. H. Passant. C. O. Pes.
use of potassitun lodide, thase re-appucants to submit any other perti.. tody, and R. G. Speirbt. "Racmedine Up-IO t^k'$ l'.Se.snuent Recovery c! the Glaad the Turoid stuces of the Bies.
I srts ar-considered, b general to r:ent studes and Uterature of whleh Inr and
!irectly proportional to the dose they are aware.
duration of therapy. and most The Comminioner abo beUeves for lhh PollontD the Administrauon ol Stible
- ity has been rehted to chronic this cecific use of potassium ladde., gee,,7;y,em pg,w,,13-sn4,5,1937O John.wn. A. E "The Rate of Returb of l
inistration (see pp. 3S35~-33:58 of and at the dosages intended. that the Ra&oiodine Uptne by the N mnal ThrMd iC, findings of the Advisory Review prescription-dispensing requ! rem ent.s Aner Suppreuion ty Phe:nacolosiat
- 1 on Over.the-Counter (OTC) of section 503(b)(1) C1 U.S.C.
DosM cf Stab!c Icdce." HnM P.unes.
' Cou gh. All- y Broutodilator 353(bX11) of the Federal Food. Druz, em 43 L 1953.
C L 'Ntp*G TI Peru on R2Wn 3 An tias *~~* t i'- D ru'
$~' rod ucts and Cosmetic Act are unnececary.
Id h I'IO-I t h' ?d '6C"3 E lshed b the Foran Rce:stra of' Only the chron!
a dministration of seu:n Couneit. :o P:rx Crescent. Lonecc.
I-l C emb-r 9,1976 (41 FR 33313)). In daily doses of potassium iodide far in
- s. Cronet. A. E t Pe,eni.. and s. c.
excess of th se necessary for thyrold-Thormc.
"~he S:eee of Smrewee by g
tio= *.o its use b pu1=cnary disor-blocking in a radlation emergency IMate of Thnoid I:cne U;n.ac. secta
- pot""O Icdf d a ts used in dady have resulted in signif t: ant side e!!ects f.un:1. t:35s 3H.1571.
s ranging from 250 to 300 mg :.n and toxttities. hese problem.s should
- 7. Din. I. A.. G. V. Arnfungerstsyn. Tu.
I rnts for up to 3 week.s in connee-not cccur f rom the short term use of a O. Ko utinunov. and L A. tantmr. -R2 with the diagnost!: use of rado-relatively low daUy dese of potaniura coeuve lomne in the Proete s of RAS 10 25 maceutical d ur products to block f odide. However, the Cr.~mNioner ad-f*u
,)
ety.
rianon S w s NC u;:take of radiolodtne by the thy-nw that the conclusion that a ;cta-g, 'C e
n et P i
glan d. ihe Com.missioner is un.
stu m lodide drug produ:: manufac* frers huout: H erds and Counter Meas.
e of report.s of sig".!!!: Ant toxjcity tured fet use as a thy old.b;ocEng um." Contract 14 D.ut Cmo-c-cn t. De-l*
ttus use of potassium iodide, agent in a radiation e=ersency is salt-fee.se Civu Pre::urenen Asen:r. c:ttee et IrN MkY. N. M. M U N y. h b N$ $k } N
,,3 a
'^-
^
w.
l e it tr:sti4n coc.:. ants *L...*/
scrwry'lt Datea wee.::.st::=.DC.. '. is. h. :t. x. et oL -Imistne Ins.6. '
- persor.s to tion and the IrAw:tlee of Ci::.1=sity et:=':b (prefershly four copies. spe.Jf g g
. cnet D=eemme in the 11uman ThyttM Oland.". Iharing ('lert doci;et t.o. Om o3 Sam et.a. 2:t M. et SL. ->t'r 9-s1 Dosaure 3
mMe 7tectdred to simp-ess 17;tsJte of wimeticsa J.c.u. sat of thfictas. 8.L.51-3"...g
,yg gg ga g
)* W End DUIE Al*
. se-121 by fier:r.a1 Thytt d." Ectrum.
IM'Z.
A bd
' IL Itadiation. A e8 Wd *IhyrcL! Cartbc.. r' imistration. IL:2. 4-85. M&O Mshtrs
.30 431. IM2.
Vatermtis. A. O. et mi. "Iodhtm.
2na. Ed:ad by I. J. DeGroot with I..L.
d Tr.rtc4cxicosis in Bea:ce." Na's J:ae 7 tot.sset 2". I. D.cls: and 3. Refeteff; LLne. RockVCI* MD. 23E51. II. s.: :6
~ ' '
Journ.r.1 e.f Medset sa. 2:7:32.3-527. 1/72. Ornde mod 3 rs? tem. ira publishen.1977.
res t!t of cc:nment: rec.0lTed es tha "
j "Res.ctor Safety 3:udy. An Assn 2 ment. J17. I.aogrt:.at:n. F. W. and J. C. Theep. ",gJidelbe 1sbfJng the Co--mtuloner '.
I l
=ciaeat RisRs b UA Cerr.esercialituch.. sen. Jr, *Proohyta. tic and 'Nraces. tic de*43~- h that th* 11Wg h-Jf M me vants. Anenes v1. cn1cursum urnsr.m :x : taw e Cent-~'~ 'ref.W. A nh 2, h M.Ashd b tametce At4ce:% Corset.rerees " UA NeeJih Phpi.m. fr.1 31 1331.1M1..
- tht* hnm*. P.IC'sT7't R.OCWhI that est Reg.aistory Cocr.=Jaalon. !!e,:4*'t L1. Pa;bl. lll. "" 1.4 C. 7. B.u : Wr. **".M such chir. es htre been Ins.2e.
- T. :ect c: y t.x. a..cio.gtext Dem. of No 1-P.s The C0"
'rbner h1I deter:n!ned 114 140c. NURZ;O IS/014 (1773).
dJoactive Ic(Jia es the Co t.>e of Ra.:'Jolo.
. Niilocal Cou.r41 cn P d's' ton Prothe*
Itepc:t No. 55. 1* rot.ecuen cf tha "I".'.y.
d:n.e U;t.ato br the Thyrcid.,"!(tr.I4.4 a*.p.
- thit this cbcur2ent de>*2 Dot conLth
~
L2,7-2 1:5.1>s2.
.
- an agency : tion covered D7 I23.1(b) m.,,. Cv.si.f. It A. et al -A Tumty Test '. ("g c.c.p'.'.5'y(the 01asd in the 3'sent of ItrJeues of F.4-
^
13
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w'.1:.e.
NL:1 cms 2 Counct.1 en Ra".in n3
.ew sf Med;cs) ybdinr2 6 s Ms:s?s2. sidera'tio:2 b ec'.:oa and Mean.rttneri'.r. Actu.st 1.
tese Popatauen w.sentany Esposess to Rs.DN1,-:c42 6.. for Irreparing stn edren ;*.n'..1
. Oeser21 Be.rdces A&~drJ4tntfon 72o.. d::metivt halout."
Re.> ort Im;7201 :: tat?: stat L3 CCt FtT31 red.
- (*
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Drtclhaven Naike.a1 I.aticestr.cy.. Upt c.
3g 13:5.
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- d. Oocd: nan. I. ZT. e >$ A. 0:l=sa.:, Nu '.* a.
24.1911.
s d
?. "A Review of the E'r21ficattce Cf UD.
g7,gy,,g,;g,(CCI l!J.Ji2 Cf Thtr'rGft:fki.
DO$M.D E
'f.
trd R4 setHnu to Ioc:ne b Pood2."
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T.-
ort of the 7sdersden of A=>erican S0.:1
.;;g w 'f d. m 301#.:2.17%. '
.Tha Esency encoura3. Interested ~~ II"It Dec.Tt-34M3 Pi.ted 131427.'- 2:0 e2aj. ..
s for I:xpert:r.rataj 1; Sole.cy und.er ?DA 8
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Studies of Nuclear Accidents by Jan Beyea The Effects of Releases to the Atmosphere of Radioactivity from Hypothetical Large-Scale Accidents at the' Proposed Gorleben Waste Treat ent Facility, report to the Govern =ent of Lower Saxony, Federal Republic of Gercany, as part of the' "Gorleben International Review," Feb.1979.
Reactor Safety Research at the Large Consequence End of the Risk Spectrum, presented to the Experts' Meeting on Reactor Safety Research in the Federal Republic of Germany, Bonn, Septecher 1,1978.
A Study of Soc'e of the Consequences of Hypothetical Reactor Accidents at Barseb*a'ck, report to the Swedish Energy Commission, DS I 1978:5, Industri-d epar t=en t e t Energikocmiss ionen, S to ckhol=, 1978.
(Also printed as Princeton University Center for Environmental Studies Report #61.)
Program BADAC, Short-term Doses Following a Hypothetical Core Melt-dowl;,
computer code written for the New Jersey Department of Environmental Protection, 1978.
Consequences of Catastrophic Accidents at Jamesport.
Written testi=ony and cross-examination before the New York State Board on Electric Generation Siting and the Environment in the catter of Long Island Lighting Co pany (Jamesport Nuclear Power Station, Units 1 and 2), May 1977.
Emergency Planning for a Catastrophic Reactor Accident, Invited testimony before the California Energy Resources and Development Commission, Emergency Response and Evacuation Plans Hearings, November 4,1976, p.171..
Short-term Effects of Catastrophic Accidents on Communities Surrounding the Sundesert' Nuclear Installation. Invited testimony before the California Energy Resources and Development Commission, and cross-examination on same, December 3rd, 1976.
The Sundesert hearings were the first held under the new California siting law.
Consequences of a Catastrophic Reactor Accident, Statement to the New York City Board of Health concerning consequences of an accident at Indian Point, August 12,1976, (with Frank von Hippel):
Co=mentq_on WASH-1400, Statement to the Congressional Subco"-4 ttee on Energy and the Environment, Oversight hearings on Reactor Safety, June 11, 1976, Serial No. 94-61, page 210.
Upoer Limit Calculations of Deaths _ Trem Nuclear' Reactors, J. Beyca, Bull.
Am. Phys. Soc. 21,111 (1976).
O e
G w
a.
v s
sy awe w PR40$+ m HYhj se 6mn
_2-CCMMENTS CF TEE CNICN CT CCNCIMTED 7 i*I U SCIDTISTS ON IMERGUCT FLANNING comitmente but no genuine review - is thus squarely in the AEctVD NUCt. EAR TACILITIES y
p tradition of avoiding the issues which arise from the 6
on July 17, 1979, the NRC published an advance notice possibility cf a serious accident such as a core meltdcwn.
f]
of pecposed rulemaking en the adeTasey and acceptance we say this not striply to chide the Comissien for past that pf emergency planning around nuclear facilities. 44 red. rev.
negligence but to point out that it must eekncwledge 41483. The notice informed the public that NEC is consi-the crucial lesson of TMI is that serious accidemts can dering adopting regulaticas which will establish as a haeoan.
It is a simple proposition, but its acceptance by conditica cf licensing that applicants demonstrate a higher the NEC would tegin to work a revolutien in requiatory J
1evel of preparedness to take action to protect the public philosoehy.
In' fact, thie proposed ruleeaking represents h
9 So too.
-W in the event of a serious reactor accident.
acknowledgaoent that such accidents can happen.
1 Befere addressing ourselves to the specific questions albeit in an equally tacit fashicn. does the staff's policy
/
on rejecting sites with pcpulation densities out to 40 miles \\
posed in the nottee, UCS will offer seme genersi observatiens.
above certain
- trip levels.*
After all, such perulations y
No
.)
The AIC and then NPC's failure to adept serious requirements are only at risk if cpe assumes the occurrence of a serious for evacuatien planning and other protective measures er to w
y tie these reTs'irements to licensing, stems directly and (Class 9) accident.
g a
However, the Cornission n**ds to af*irnatively wipe
.d o
inexorably from the ageney's refusal to face forthrightly _
the vastiges cf a fatally flawed requ1 story policy and
,e t
cut the possibility of a major reactor accident which wculd result in radiation doses offsito. It has been a historical require the consideration of serious accidents in all aspects f
of licensing. The discredited "proposad* Annax to 10 CTR F
hallmark of U.S. nuclear regulatory philosophy to deny the Part 50, excluding Class 1 censequences frem 5!PA review credibility of a so-eslied Class 9 event. The consequences b
should be immediately withdrawn. The present system is f
of a major accident are systematically excluded *ron impact m
s9 well rationally
/
logically and philosophically incensistent statements prepared pursuant to the National Environmental f
insupportable.
Policy Act.
In like fashion, Class 9 accidents are not Finally, emergancy plannir:9 issues are tied closely to considered as
- design basis events
- and no measures are required to mitigate their effect. The NRC's ambivalent siting policy. There are presently seme operating reactor V
P sites where the number and ceneentrstion of surrounding F
attitude toward scor;ency planning - requiring lip-service 5
population nake it a practical inpossibility to taka prot =ctive b
d P
0 N
d g
trMM.Tik:hMd%. ~ M:LWL&hMsgggggrgy..rm;;.;qnm w.
p.,
-y.,
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g;
y _ =. c x.:.
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. _.. = =
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b 4 measures. No one yet knows how many such sites exist, but certainly Indian Point, near New York City and Zion, near objective would totally undermine public confidence in the Chicago, present essentially intractable problems. All safety of the population living near reactors.
)
operating reactors should be reviewed on a priority basis reasible laplementation of emergency plans must be a to determine for how many the environs are unavacuable as prerequisite for siting approval for new reactors in order a practical matter. These should not be permitted to to insure public safety. where existing reactors cannot operate. In addition, future siting should be restricted meet feasible implementable emergency plans to provide for to areas truly remote from population. This would be a public safety in event of a core meltdown, licenses should major step forward in learning the TMI lessons.
be revoked until such time as an isplementable emergency The re:nainder of CCS's cocuments vill address the specific plan has been demonstrated, CUESTfoN questions posed in the published notice.
(2) What constitutes an effective emergency response l
cursTIort s (1) What should be the basic objectives of emergency plan for State and local agencies? For licensees? What are the essential elements that must be included in an planning?
C w
effective plan? Do existing !!RC requirements for licensee s 8
(a) To reduce public radiation exposure [
(10 CTR Part 50, Appendix E) and guidance for states (NORzc.
75/111) lack any of these essential elements?
(b) To prevent public radiation AN8"ER' sure?
An ef fective emergency response plan must be tested and (c) To be able to evacuate the public?
proven irnelementable as judged by a number of responsible To what extent should these objectives be local, regional, state and federal. officials. Perhaps the quantified?
keynote of feasibility is that there must be persons with ntswn both technical information and expertise in combination Prevention of radiation exposure to the public should with decision-making authority in a position to judge whether be the basic objective. This is tied directly to evacuabi.
ke) a danger to public health exists and to implement protective lity.
It would be irresponsible to qualify or ccmprcmise cn acti n.
This was, mf course, sadly lacking in the Tx1 case.
this objective. Furtherscre, any qualification of this We>
~
3 TP W
Ms"
I
~
l
+
-e-j The Governor, who had tha authority, did not have access to airplanes and ships.
I accurate information, at least within the critical time Fresent NRC practice is totally inadequate, although periods.
- Y
- " I"T hi
- A*
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I "* ** ""
State goverr.ments should either e:nploy or contract
~
appropriate local resident specialists in nuclear physics,
- *** ~ **
nuclear engineering, chemistry and biology giving them.
- *^
responsibility for regular inspection and criets intervention
(
which chargos them with making declaration of a pending public 1) it does not require any detailed implementa-safety emergency simultancously'to the licensee, chief elected tion plans at either the construction Pemit or operating 11censo stages, official or local and regional governments within a 50 mile it does n' t require any testing or actual 23 o
radius and the press.
field verification. Essentially, it requires only paper, and vague paper at
- The U.S. EEW process for emergency medical care coupled
- that, k.
with the of ficial health planning agencies for states and 3) it contains no performance criteria whatever against which this paper can be judged, g'
their sub-stata regions should bear the responsibility for W
4) this is compounde$ cy the fact that there is 1
assessing the plan's f easibility of meeting emergency response no guidance of fered to the agencies charged c) with the responsibility to take protective w
frca a health perspective.
action on what the health and safety conse-f quences could be of the range of pctential
- The transportation systems must have adequate capacity accidents. Thus, the Governor of Pennsylvania had to ask the CorJsissioners in the middle of to acccmodate the number of people evacuating because of a the TMI accident what the consequences of exposure could be and was told by the Chairman public health safety hazard in the affected area within a that there is no good information on the sub-ject! Meanwhile, of ccurse, the plume had set period of time (6 hrs). Judg=ent pn this aspect of an already passed, p,
emergency response plan can best be made through the prccesp 5) it does not specify that the
- design basis" for (mergency planning should be e Class 9 U.S. CCT uses to approve transportation development projects.
accident, or provide parameters for evaluating f
Cr the range of potential releases. Therefore, the areas covered are far too small.
- Significant federal planning resources already enable each of the naticn's *
- 'JO's" (metropolitan planning organizatione CtJESTION r of chief elected local and state officials) to know their (3) Should NRC concurrence in the associated State and y;
capacity limitations for road vehicles, rail vehicles, local emergency response plans be a requirement for continued I
[C) operation of any nuclear pcwor plant with an existing cpera-4 i
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ting license? It so, when should this general requirement v
bacose sffective?
for the issuance of any new operating license for a nuclear MSWER:
power plant? If so, when should this general requirement Tcs. Prior NRC concurrence, cencurrence of the become effective?
MswtR:
gov:rnor(s), the chief elected local officials within 53 Eiles cf the site, and the concurrence of elected legisla-Yes - immediately. And a much more detailed showing tura cfficials (local, state and federal) for the same of the suitability of the site for evacuation and/or appro-
, }'
grographic. area should be required on emergency plans for public safety and evacuation. This concurrence must be a satter of public record and official sign off should take -
piecs subsequent to a month long period of local distribu-tion of public education materials coupled with a drill on ccid emergency plan.
The requirement should be isuadiately effective for even of women and children within S miles would have produced g
existing plants in an area where population within a 50 alla rsdius exceas 1,000,000 people. Other plants is (5) should financial assistance be provided to state
)
rperssly populated areas should have a deadline of 6 and local governments for radiological emergency response mcnths to operate prior to plan approval.
Planning and preparedness? If so, to what extent and by URC must find, as to each operating plant, that the what means?
'affected public can be protected in the event of a Class Cm]
What should be the source for the funds?
ggyg,,
0 9
N 9 accident. There are a number of operating reactors for Absolutely. The level of funding rsquired should be which this is clearly not the case. Indian Point and tion derived from national standards to be met set by NRC are two obvious ones. These plants are a real threat to G
)
together with REW and DOT.
The licensee should be obligated
- public safety.
to pay the municipality, any affected regional government.
/;
QUESTICW
~*
bC and the state (each in separate transactions) 509 of this (4) Should prior Mac concurrence in the associated W-funding annually from the filing of an application for a
, State and local emergency response plans be a requirement 7d e,
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i ; license until said plant has been deccamissioned long Enough to present no further potential public health State and local civil defense agencies should assume I'
and safety risk. The local,'regicnal or state government the lead with proper training frca the NRC as closely thould annually appscpriate the other 50%. Should any monitored by the state's corsaittee of technical experts 8
of these governments in any year f ail to appecpriate described in the answer to question (2) above. At least g
their share the licensee should be obligated to shut ene drill should be held before the public and their down until such appropriation is made.
officials sign off approval on implementability of the CUEST!cN plan.
(6) Should radiological emergency response drills be cursTToN a requirement? If so, under whose authority
- raderal, (7) How and to what extent should the public informed, State or local government? To what extent should rederal, prior to any emergency, concerning emergency actions it i-State, ar.4 local governments, and licensees be required to might be called upon to take7
(-
participate?
ANswrns AffSWR s Tne CAO investigation cited above found that the only w
Yes.
GAa concluded in its recent report to congress efforts at informing the public about possible emergency l
-d 1/
9 cm this subject,- after site visits to eleven nuclear action were public meetings called by utilities during the 3/
i f acilities and analysis of quasionnaires to all states, licensing process - years before' actual operation.~
No
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that untested plans "would probably be ineffective in an further actions were taken to info n the public. Ucs l
2/
emergency situation.*~
Thus, an untested plan is worse believes this failure to be little short of scandalous.
I than nothing at alls it provides a falso sense of security CAO stated:
and iulls people into complacency.
Facility operators did not appear ccncerned about the lack of informaticn made available to the public. This reflects the attitude of most operators, namely, that there is little danger 1/ " Sites Around Nuclear Facilities should Se Better Prepared to the public from their facilities. This attitude for Radiological Dnergencies," r.MD-78-110, March 30, 1979.
was summarized by one operator who said that he i
did.not expect serious accidents requiring large-2/ Id. p. 11.
scale public involvement to occur and that prompt y
5@
3/ Id. at 28-31.
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L I L notification and normal local offsite emergency response actions would receive total public compecmising cn a *1ess severe Class 3 accident." There r
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cooperation if a nuclear emergency did occur.
is no excuse for this temporizing. The reconnendations
{
In most cases, the cperator's confidence of the Joint Task Force, with this important change, g
in public cooperation has not bcon put to the g
test, even on a limited scale, to determine its might usefully serve as the focus of the ruleriaking pro-validity.
Thors can be little question that the public needs to ceedin7 However, that should not be permitted to ser re know what to do in the event of an emergency. This requires, as a wedge for prolonging Consission inaction. It should l
l '-
act lavnediately to require licensees to have NEC concurrence the distributien of information, by mail, updatad annually, to at least the present requirements.
to all persons living within 50 miles of a plant, of proce-l CUESTICNs dures for evacuation, the location of evacuee centers, the (9) How and to what extent should the concerns of location of medical facilities, etc.
In addition, the State and local governments be incorporated into Federal utility should be essponsible for arranging widely-advertised radiological emergency response planning?
public meetings in esch affected city or town to bring MSWER:
tcgether the responsible officials and the piblic, to review Ca It is irresponsible not to heed state and local concerns the emergency plans.
8 as, in the last analysis, they are the people who are most CUESTicN impacted by the accident -- living with it, and recovering f
(S) What actions should be taken in response to the from it.
They are in a position to turn any theore*1 cal recomendations of the joint tTRC/ IPA Task Force Poport emergency response planning into a workable reality. In (Nt;EIG-0396/ EPA 520/1-78-016) ?
C addition to all the comments in other responses to these g
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questions concerning their role, it is critical that en The Joint Task Force Report represents a significant an ong ing basis scate, regional and local officials have step forward in bring this issue into the light of day better access to training, data and other information here-but does not go far enough. There is insufficient justifi-t fcre nly h used with f ederal officials as well as data cation for limiting the Emergency Planning :enes for plcree g
g and other information heretofore considered proprietary.
exposure to 10 miles. As indicated above, we suppor-the Sc A
As a pra tical matter, the involvement of numerous use of a Class 9 accitant as a planning basis for emergency f
a swornment a ss uati n tends to create y
action. The Task Force fudges badly on this, apparently tq y confusion, diffuse responsibility, and weakened accountabi-C1=
=,
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e e
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fhdh acs anmE2 M M ""
tity. rhe only effectiv. ay to holt together the hoto 9 = 122 t
is for one organization to assume supervision, and the
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enly effective wedge is the interes*
- .* licensee in osmaer.e r e,.avve.i. assowacas
(
i.ese, a cs.sr.6 re.e.e iste.rw continued operation of his plant. yns L. ore, the super-e** ".*.'.t e""me*n **
e
. pous vision has to be in NItc, which can enforce it.
Cader afRC's review, licensees should at least annually Ausset 29, i m contact each responsible state and local official, make 8.cretary of the Commission sure that ha/she understands and concurs in his/hn sole
',$'*IN C*""I o7' 4
g in the event of an emergency and solicit conunents on the C
RE: Advance 3etice of Freposed n n.as, sus.cy e.d V
need,'if any, for changes.
.9 SEP 6 t!13 ) 12, g,,,ptance of teergeecy piamaiss By the Unica of Concerned
""".e Around seclear Facilitias*
Scientists
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(rt aat 13s. T.esday.
y dely"I;,g,79)
A e2 U
Cear Mr. Chilk f
$11 LA. Weiss it appears free the seserficial nature of the westtaes la the subject Y
a g
General Counsel Federal Register metice that the mlC is act yet f amiliar with the real world b-N prebtesa inherest ta pubtle pisaning for emergencies at nuclear power plaats.
Cafertaastety. most state and tecal civ11 defesce coordinatori, de are eery g
f ala11er with their local situations, are est yet feel!1ar with the detailed I
Jh ceasequences of the reacter accidents for 41ch they must plae. Cat 11 the m
31C can educate the civil defense plassers as to resitatic valese and Carla a. Jchasten taterrelat tenships of parameters each as the varaing time before release. t*.e cepaty Director L
Union of Concersed Scientists durattaa of reteese, types of material released, the time of plaae passage.
the extent of ground costaalaaties. the deoe-res.cties ef fects of sheltaries la i
Cambridge. 'tassachusetts bu11 dings of verteus types, etc., the planners caseet ef fectively optimise,
CATED: August 31, 1979 altigat1*e meneeres for the agecific plant sites withis their jertsdictierus.
until this sep to bridsed. ewhetantive impre ement la pubtle protecties f rom a nuclear accident casset be expected. Cat 11 the l0LC becomes familiar k
with wat cas and eat cameet be accomplished by saformed and 1ste1114ent letal emergency planning, additional NltC regtalattee is 11kely to be of f. base and s1C " concurrence
- weald be meestagless.
F C
prior ta the tecident at Three Mlle Island Unit 2. the need for a better baste for tocal emergency planoice was reccgetred by ttA and NRC. Their h_
h joint document draf t QUIC:-0396/1FA 320/1-76-016) 1ssued ta tecember 11F8 was a teamanable beginalog for improwesent. $1m11 arty. CAO's Report to Cergress la 30 terch 1979 recognized the need for better preparattaa la areas around euclear power plaats. It is trenic that the tecidest at tt!. durits dich the maximum deaes were en order,ef maanitede lower them the EPA's guide 11ae M) values for taking even velentary protective ac!!en, acw threatens to aesate
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this begiasing by forcing pick rather than sebetantive actions.
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E page Teo page D ree Mr. Chilk Mr. Chilk August it.1979 deguat 19, 1929 Rather than attempt to direc:17 auswer the queattor.s la the Federal Register motice, we effer several potats for your considerations sod op meklag tapessible er carealistic demands, ettber free their cwn A.
The planning for esorgencies at aucteer power plaats is intensely idearance er due to political pressere. If the pc originally approved site-stecific. It should be coanidered is a realistic amaner derirs a site for a nuclear power plant. it eheute be able to show by specilia site selection and approval. For this perpen.10Cy1100 is preseocly
- 88"ple that as acceptable emeraescy plan can be made for it.
taaf aquate, se are current 3RC 8sgulatory Geldes on populattoe density.
F.
If the MC concurrence is requirat for emergency plane withis a 50 mile 5.
C1ves the variety of sites currently approved for auctaar power radius of a reacter site it must have a glas for deslics with state plaats by NRC, standariaed national guidelines for emergency planning borden and uncuperathe or unrespnstre eetghhen. Is the east, are not likely to sigaaficaatty taprove the emergency plans. Population few Pe*er planta have 50 mile rallt coetatoed Wo117 withia a stagle state. EePeelelly if a time constraint is imposed, each stata can be density. physical barriers to evacuation, types of shelter eva11able.
and other deacgraphic factors differ to e degree which def tes a espected to place priority os plana for sites wi:his its borders, and genera 11aed planning concept. Sasething general etaugh to be app 11able
- y*
if necessary, neglect planning ta their portions of 50 alle rings of distance plants. Utth rivers servleg as borders for states. service everywhere is vailkley to be specific enough to ensure realistic plannir.g territories and eyes interconnected utility groups power plants at an yd e re.
many rivertaa sites could have little importance to the jurisdictica directly acroaa the river.
he threat of shutdows may to inef fectual C.
The NRC should provide auch eure specific detail about the kind of situatious for which the planners must prepare. Scenarios stallar to La producing adequate speed la suh cases. If speed is desired, thee the E87 **11 e to provide it Woogh adequate assistance, not the ratesse catagories of the ceasetaeaces model la the Reactor Safety
- "I
Study would te a each better beets for developtog plans them is y
curreetly provided La the "pluma zones
- and "logeettoo sones" of 3CREC C.
During emergencies, plant personnet shod 14 be expectai to rotata centro 1.
0396. The NRC should exercise its judgea,ent ta def taing these scenarios g,
00 so as to exclude those potential high-consequence accidents which are design of one hundred dif ferent reactors and contret races to the 00 of suffielently low probability to pose acceptable risk levele without degree that they woeld be preferable to a well trataed group of the plancios beyond that level already required by the more irobable accidents.
ut111ty's employees. The MC could improve the current st:eaties It should also consider the uncertainties which were apparent during the by developing regulations and guide 11aes for emergency at:uation til incident. and help provide a rational bests for action during a period tra1 ming programs which stility companies would develop for seater shee eulstlag conditious de not require actica but future detrioratica operators at each of their reactors. A cadre cf 3RC personnet should be of the situatloca may occur.
developed to focus expertise os emergency ottuation tastrtmetation.
si el C1 e and training. This 3r up could aise be made available as D.
The NRC should make available to the local planners the te#*1 cal 7
e nau ants ur cg as actua emettency, s out time permit.
l Anformation regarding ef fectiveness of various *ypes of si;.;a:1re I
measures a1staat the various dosa pathuays* expected under -- 41 dent h-
)
to summary, we erge that asertency plannies for mudear reactors be conditions. Por instance, for plume ahtaa. ichalation and surf ace substaattally improved, but we caattom agatast hasta. The emphasis on timirs.
I contaalaation doses, dose reluction factors due to sheltertr4 La rather thaa substance in the Federal Register notice is 111 atvlsed, althoug%
bu11diras of various constructica types should be made available.
understandable in the face of pub 11e opinion.
E.
The NRC should provide both techotcal and planning assistance te
$1pcerely,
(
the state and local civil defense personnel. If the NRC adopts regulations requiring afequate emergency p.ans to le taptemented by a
(
spec.1fic date, then NRC should be preparat to supply suf ficient consulting personnet to help all affected state and local plannen i'
to prepare their plans within the tae allowed. The NRC should be Steven M. tang. ph.D.
C'6 Aetlag Director
,(
prepar=1 to provide ao example of an acceptable plaa for any plant power plant Siting preg ram f
site where 1: feels that local officials have not plannet adequately.
[
3 Vithout this level of commi: ment on the part of the NRC.1: is probable that the JRC personnet reeleving the plans will in man; cases.
ggg y, ces peut Itassicot. Ac:ing Direc:or -
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t..rg r u.laiser.tt t
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. _ _ _ _ _ _ _ - _ _ _ _. _ _ _... _ _ _ _