ML19309D194

Statement Before Ny City Council, Impact on Ny City of Reactor Accidents at Indian Point, (Corrected 790620)

ML19309D194
Person / Time
Site:	Indian Point
Issue date:	06/20/1979
From:	Beyea J PRINCETON UNIV., PRINCETON, NJ
To:
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ML19309D167	List: ML19309D166 ML19309D194
References
FRN-44FR75167, RULE-PR-50, TASK-OS, TASK-SD-906-1 NUDOCS 8004100127
Download: ML19309D194 (49)

Text

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l The Impact on New York City of Reactor Accidents atIndianPoint Statement to the i

New York City Council June 11,1979 (CorrectedJune 20, 1979)

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l Jan Beyea Research Staff Center for Energy.and Environmental Studies i

Princeton University l

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l 8004100127 1

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h 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 temperament 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

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of accidents at the Barseback reactor which I carried out for the Swedish Energy Comission, 2) the dose-prediction computer code, which I wrote for 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) the study of potential accidents involving spent-fuel rods carried out for the state of Lower Saxony in West Gennany.

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-1400 (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 signifii: ant and called, as a result, for accident mitigatory measures in my European studies (similar to those which my colleague Frank von Hippel and h'.s cea.::nors ir, che.

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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 plannina be carried out for cities such as Malmo (which lies within 10 miles of the BarsebSck reactor) and Copenhagen (15 miles away) -

something which seemed radical to nuclear proponents, and engendered much criticism, before Three Mile Island.

This critical public posture has not endeared me to the nuclear establish-On th'e other hand, the fact that I refuse to call for the shutdown of ment.

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 sqy technical studies of accidents at Indian Point.

I will discuss 1)the probability of serious accidents at Indian Point, 2) the consequences of such i

accidents for residents of New York City, and 3)actionsthattheCityand 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 elements of an emergency plan suitable for the City. Second, that a study i

of alternative's to Indian Point be funded.

Accident Probabilities It is now clear that the nuclear industry has failed to produce a system i

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 probability of bad accidents perhaps a thousand times higher than assumed at the start of the 9

4 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.' One learns 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 am aware that many people find it difficult to believe that scientists and 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 Bfown'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'should 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 reactor-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 grounds 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. reconinendations, 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 Islan'd.

Such a plan is not yet required by Federal law.

l It is up to the City Council, the Mayor, the State 1.egislature, and the Governor

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l 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.

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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 cesium in the 9

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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 releases 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 order to be prudent, therefore, we should develop our contingency plans on the presumption that there is a s.ipnificant 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

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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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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 overpressure.

(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.5 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 cancer' deaths for periods of time measured in decades.

It is the cesium and strontium which are ordinarihy considered to be the principal long-tem land contaminants.

Table III indicates in more detail the time frame of received doses.

i 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 -tem".

(See Table IV.) Sickness and death within two months from radiation-illness would be a ris'k for people caught in very high dose regions (more than O

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-l 100 rem to the whole body). The chances of such high doses esecurring 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-tem 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-tem effects would inevitably occur in the city should the wind be blowing this way.

The magnitude of doses received would depend upon meteorological conditions 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 a 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 Regulat::ry Comission's Reactor Safety Study.0 Aoderate Release Case:

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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 l

would equal or exceed certain values.

For simplicity I will focus on doses 35 i

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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 expos 9 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. T'he individual 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 l

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 l

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200 to 1600 of them being fatal.

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PWR2 Accident

)

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 ccm. unity would be exposed.

Figures IV, V, and VI show area contours for various doses.

Table VIb shows the major health consequences from the inhalation and cloud shine doses plus one day's exposure to contaminated ground. Most of the exposed population would develop thyroid nodules which wuuld 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 cancer deaths are predicted to result for a wind direction exposing one million New Yorliers.)

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-term 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 l

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.

. e Over tha years, some of the radiation 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 released radioactivity, would be a source of continual worry for residents of other areas.

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G 11 Alternatives to Indian Point Ideally, before making decisions, political leaders should be informed I

about the side effects of each energy option. My purpose bere today is to I

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

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i problems with other energy options. One should not lose sight of the fact that fossil fuel electricity sources (which might be increased ifIndian Point i

were shut down) have equally as shocking health effects associated with them.

It is not generally known, but still true, that air pollution from oil-and coal-burning plants kills people.

Estimates range fran one to 100 deaths to the public per average 1000 megawatt plant per year.II 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.

i Thus, one must not leap to the conclusion that all alternatives to Indian Point are preferable. Reactivating oil or coal plants in New York City could be construed as condemming 100's of older residents each year to premature deaths.

The decision about which option 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 net involve i

dramatic increases in air pollution, and it is to those alternative we should

e 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

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(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 firms 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.

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), onde in Sweden and once in West Gemany, and recomend this approach.

Obviously, such studies costs money.

I estimate $100,000 would be necessary,

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for the non-utility study.

Perhaps there is some way that the utilities could be e

-13 assessed the feet 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 fu;tding.

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partial evacuation might still be necessary after the passage of the plume. The :

faster that people could be removed 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 l

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 infomation about sheltering. Local radio stations could be used to relay the instructions which might be needed.

It is not easy to design an emergency plan that, remaining unused for years, would work on comand. The only method in which I place any confidence i

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, comunication procedures are constantly checked.

Such comunication 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 Mayor set up a task force to

• develop the outlines of a New York City emeroency plan for reactor accidents.

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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o 2.

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 accidents.

Nevertheless, potassium iodide is cheap (it is the fom of iodine added to iodized salt), and could significantly reduce the number of people 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

'trectly to dose and duration of therapy. The risks from s;'rt-tem use of relatively low doses of potassium iodide in a radiation emergency are outweighed by the risks involved from exposure to radioiodine.

Almost complete-(greater than 90 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 potassium 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.

A 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' production on an emergency basis and within a few days had e

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 procurenent 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. Conmissioning 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 sacely needed.

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-18 Footnotes and References N

1.

Reviews of Modern Physics, 47,, S1 (1975).

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!f The design goal for the probability of complete failure of reactor safety syster;:

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g was less than one-in-a-million per reactor year of operation. This goal nn was assumed to have been achieved until 1974 when the authors of th U.S.

Q Reactor' Safety Study (WASH-1400, the so-called Rasmussen Report) estimated p5 4

a meltdoh probability some 50 times higher (one-in-20,000 reactor years) 13 based on a deta'iled analysis of certain accident modes.

5 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

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accident considered in the RSS (PWR9), with a lower release into the con-

)7 tainment than actually happened at Three Mile Island, was assigned a probability on one-in-4000 reactor years. Yet, the Three Mile Island w

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.n accident occurred after a total experience of only about 400 reactor years (cummulative total).

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Reasons why people wouli! tend to underestimate failure probabilities of complex systems such.as nuclear reactorswere discussed in the psychological J1 literature before Brown's Ferry and Three Mile Island.

See A. Tversky and y

D. Kahneman'. Science 185, p.1129 (1974).

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One reactor-year is taken here to mean one year's operation of a 1000 Mw(e) pc l$i plant. 400 Reactor-years is equivalent to 80 large reactors operating for p.

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.

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To obtain sufficiently high doses one of the following events must occur:

1) neavy 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 previous 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.

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Jan Beyea, " Consequences of a Catastrophic Reactor Accident" Statenent to the New York City Board of Health. August 12, 1976.

ThisrefereNceaccidentdifferssomewhatfromthatchoseninthesecret 8.

Brookhaven report (WASH-740 update) often referred to. by anti-nuclear activists. The Brookhaven report assumed a 50% release of everythino in the core, whereas WASH-1400, based on later experimental data, assumed i

a higher fraction for the most volatile isotopes, but a much lower fraction

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for non-volatiles. This leads to a 2 times lower short-term dose and synewhat shorter distance range of airly lethalities for the accident con-sidered here.

There should not b'e much difference in the long-term dose.

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Nevertheless, the Brookhaven report projected, in the worst case, a land contamination figure five times higher than I would project.

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i know yet whether this is due to the different release fractions assumed or due to different land contamination criteria.

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A 10 rem n 30 year threshold level has been used. This is equivalent to the crite-ia used in WASH-1400 for rural land, but not the 25 rem in 30 year thres5ald assumed for urban land. However, 25 rem in 30 years appears to be higher than that recomended by the International Comission on Radiation Protection, (See WASH-1400 App. VI, Ch 11.)

A 10 rem dose implies a fatal cancer risk of a few tenths of a percent, assumirc four hundred cancer deaths per million person-rem figure. This dose cceffh.ient 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 on ionizing radiation makes use of the relative risk model.

10. The micron-sized aerosol particles would attach themselves strongly to surfaces. To ' decontaminate, it might be possi'le 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 pollutan.t levels.

The results are higher than would be expected frem known effects of sulphur compounds, suggesting synergistic effects with other pollutants.

See, l

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Trace Contaminants from coal, S. Torrey, Editor Noyes Data Corporation, 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-nesf*, 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.

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For comparison, note that the 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 per 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 l'I Inversions ( E'& F) 41%

, Neutral (D) 31 %

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Unstable (A, B, C) 28%

4 Wind Rose Data (for the 300 ft, tower) suggest the following relevent percentages:

Percentagecftimethatgind Percentage of time that wind f

direction lies in the 45 direction lies in the 900 sector including New York City sector containing the New York I

metropolitan area with 3

Inversion (F&E) 6%

11%

Conditions with Neutral Conditions (D) 10%

20%

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ns (A, B, C) 6%

9%

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Total 22%

34%

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TABLEII PROBABILITYESTIMATESFOR"kCCID5NTS AT INDIAN POINT OVER 30'VEhR LIFsTIME TYPE OF ACCIDENT PRosAB'ILITY.

=

1)

ONE WHICH SHOULD TRIGGER EMERGENCY RREFARATIONS IN llEW YORK LITY, BUT' WITHOUT A LARGE RELEASE OF RADIO-ACTIVITY ACTUALLY OCCURRING 15% )

A 2)

ONE WHICH LEADS TO A LARGE RELEASE OF RADIOACTIVITY WITH THE WIND ((Q_T.

1.5%(SuBgCg BLOWING TOWARDS THE CITY 3)

ONE WHICH LEADS TO A LARGE RELEASE OF RADIOACTIVITY WITH THE WIND BLOWING TOWARDS THE CITY CAUSING )

,3% (SU

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CANCER AND OTHER HEALTH EFFECTS C 4)

ONE WHICH)CAUSES EARLY DEATHS IN

.03% (SUBJECTIV THE CITYD ESTIMATEl A)

HALF THE FRE9UE3CYhBICH HOULD BE OBTA,JNED FRCM THE OCCURANCE OF THE DRQWN S

-ERRY FIRE AND THE IHREE IIILE ISLAND ACCIDENT, i

(SEE TEXT).

B) hSSUMINGTHATl-IN-10ACCIDENTSLIKETHEBROWN'SFERRYFIREAND IHREE MILE ISLAND LEADS TO A LARGE RELEASE.

C)

BASED ON A 1-IN-5 CHANCE OF TH8 WIND BLOWING IN }UCH A WAY THAT A SIGNIFICANT FRACTION OF THE PLUME PASSES OVER LITY TERRITORY.

D)

SEE FOOTNOTE 6.

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uw TABLE III 3I A.l TIME FRAME OF ' RECEIVED DOSES

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IMMEDIATE DELAYED M

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FROM PASSING CLOUD.

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FROM INHALED RADI0 ACTIVITY STORED IN THE BODY.

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WHILEREMAfNINGINCONTAMINATED 2)

FROM GROUND CONTAMINATED GROUND BEFORE EVACUATION.

TO LEVELS TOO LOW TO

~?

JUSTIFY EVACUATION.

M 1.n L9$

TABLE IV p

TIME FRAME OF HEALTH EFFECTS g

Lt IMMEDIATE DELAYED SICKNESS AND DEA"H FROM DOSES.

CANCER, DISEASES, DEVELOPMENTAL a OF THE ORDER OF.00 S.0F REMS.

AND GENETIC BIRTH DEFECTS jj OCCURRING WITH DECREASING BUT g;

NONVANISHING PROBABILITIES WITH s

' DECREASING DOSES.

{

br:

cw M

E1 Ed a

S,-'.

TABLE VA APPROXIMATE DOSES IN REM RECEIVED 35 MILES AWAY FROM INDIAN POINT FOLLOWING A " MODERATE" ACCIDENT )

A DOSES TO.

THYROID GLAND DOSE TO WHOLE BODY ADutTS' CHILD N

UNDER FROM INHALA ION AND B

CLOUDSHINE

.2 REM 60 REM 300 REM PLUS 1 DAY'S GROUND C

EXPOSURE 5 REM PLuS 7 DA 'S GROUND C

EXPOSURE

.9 REM PLUS 2M0yTH'SGROUND C

EXPOSURE 1.6 REM A) 5% IODINE, 60% XENON AND KRYFTON.

"D" WEATHER STABILITY, l

10 MPH WIND,.01M/SECDEPOSITIONVELOCITY,25METERPLUME L

RISE, WASH-ll400 DISPERSION COEFFICIENTS, GAUSSIAN PLUME MODEL.

1 B)

CLOUD SHIELDING FACTOR = 0.6.

C)

GROUND SHIELDING FACTOR DUE TO 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 AEitOSO PARTICLES CARRYING THE RADIOACTIVITY.

TABLEVB MOOR HEALTH E/FECTS AT 35 MILES FOU 0WItG A f0DERATE ACCIDE?E Ob IODIDE BLOCKliG ASStMED)

PER MIU_ ION FOPULATION EXP A

DEMYED CANCER DEATHS )

B FRm.2 REM INmLATION AND ' CLOUD SHINE 10TO100 FRcn 1.4 REM GRO'Jta DOSE 70TO700 CASES OF THYROID NODULES eD)

FRm 3T REM TO CHILDREN 12,@ TO 60,WO FROM60REMTOADULTS

-3,000 To 40,000 IbN-FATAL THYROID CANCERS '

CHILD 600 TO 3 E ADULT 800TO5,000 FATAL THYROID CANCERS,d C

CHILD 22 TO 120 ADULT 100 TO 700 l

A)

IF THE WIND'WERE BLOWING TONARDS MAN!%1 TAN, THE EXPOSED POPULATICN IN NEw YORK CITY MIGHT NLMBER 3 MILLION, WHEREAS IF THE WIND WERE BL%ING TOWARDS STATEN ISLAND, A MUCH St%LLER NWBER OF CITY RESIDENTS WOULD BE INVOLVED.

B) M SED ON 50 lu 500 DEATHS PER MIU ION PERSON-REM. SEEFOOTFDTE14.

C) THYROID DOSE /EFFECT COEFFICIENTS TAKEN FROM R=v Von PHmcs, 47, S1 (1975).

D) MSED ON A COEFFICIENT OF F5-ST CASES PER MILLION THfROID REM AfD THE ASSLMPTION TIMT 15 PERCENT OF THE POPUMTION ARE CHILDREN LESS TMN 10 YEARS OF AGE. ItCIDENCE OF NOD'JLES FOR ADULTS TAKD1 AS 1/211%T OF CHILDREN, REM FORRE4,BASEDON1978PMRSMLLESEDATA.

E) EASED ON A Cor.reICIENT OF 12-75 CANCERS PER MILLION THYROID-REM.

F) EASED ON AN ASSLMED @ MORTALITY FOR CHIU)REN,15% FOR ADULTS.

o TABLEVIA APPROXIt%TE DOSES IN REM RECEIVED AT 35 MILES FRCri INDIAN POINT FOLLOW!?G A P,R2 ACCIDENT.A)

DoSETO 9

M ID b DOSE TO TS QIDREN WFOLE BODY uteER 10 FRCH INmLATION A?O CLOUD SHINE )

Il REM 10W SM B

PLUS 1 M Y'S GROUND EXPOSURE )

32 C

Plus7 DAY'SEXPOSURE) 32 C

PLuS 8 WEEK'S EXPOSURE }

66 A) "PrR2" ACCIDENT RELEASE FRACTIONS TAKEN FROi KASH-ll400. 10 MPH WIND, D STABILITY,.01 MSEC DEPOSITION VEliCITY,150 METER EFFECTIVE RELEASE HEIGHr, MASH-ll400 DISPERSION COEFFICIEtES, GAUSSIAN PLLME tODEL.

B) CLOUDSHIELDINGFACTOR=0.6.

i C) GROUND SHIELDItG FACTOR = 0.2.' (THESE DOSES ARE UNCERTAIN TO AT LEAST A FACTOR OF 5 DUE TO UNCERTAltEIES IN THE " STICKINESS" 0F THE AEROSOL i

PARTICLES CARRYI?G RADI0 ACTIVITY.)

TABLEVIB IWm HEALE EFFECTS FRm INmLATION, CMXJD SmNE, AfD 1 DAY'S EXPOSURE TO CONTA'il?MTED GROUND AT 35 MILES FOLLOWIfE A P<R2 AC p

(fb IODIDE BLOCKItG ASSLNED) 1 @ M [f]

DEIAYED CANCER DEATHS )

600 TO E PER MILLION PEOPLE EXPOS B

C TWROID EFFECTS )

VIRTUALLY ALL EXPOSED CHILDREN'S AND A D

LARGE FRACTION OF ADULTS' THYROIDS WOULD DEVELOP tODULES. A LARGE FRACTION OF THYROID TODULES WOULD REQUIRE SURGICAL TREATMENT AND LIFETIME MEDICATION THEREAFTE DEVELOFMENTAL DEFECTS MICROCEPMLY (SMALL HEADS)3 l @ OF EXPOSED F0ETUSES GENETICDEFECTS PERSONS WIE IDENTIFIABLE D WINENT GENETIC DEFECTS OVER AN AVERAGE OF FIVE GENERATIONS )

E TO 30I PER MILLION PEOPLE EXPOSED,F)

B C

A) SEE IABLE.VB Fm DOSE COEFFICIENTS USED. THEONEDAYGROUNDEXPOSUREREPRESE AN OFTIMISTIC ESTIMATE FOR AVERAGE EVACLWTION TIME.

B) FROM12REMEXPOSURE.

C)

IF THE WIND WERE BLOWING TOWARDS NWPATTAN, THE EXPOSED POPULATION MIGHT NLNBER 3 MlluCN, WHEREAS IF THE wit 0 WERE ELOWItB TOWARDS STATE ISLA!G A MUCH SMALLE NLNBER OF PEOPLE WOULD BE INVOLVED.

D) 10I REM TO ADULT, SC00 TO CHILIREN UtOER 10. tbTE TMT BECAUSE OF THE LARGE tRNBER OF THYROIDS WHICH WOM MVE TO BE REOVED SURGICALLY, THE ItCIDENCE OF CANCER WOM NOT BE THAT HIGH.

E) RW-lliOO, TABLE VI F-9.

t F) EASED ON TABLE )@VIII 0F Revs Tbo Pwsrcs,147, S1 G975).

" TABLEVIA APPROXIPATE DOSES IN REM RECEIVED AT 35 MILES FRm INDIAN POINT FOLLOWING A RR2 ACCIDErrr.A)

DOSETO DOSE TO T m ID 6 ADULTS CHILDREN N BODY UNDER 10 FRm INHALATION AND CLOUD SHINE )

4 REM 1000 5@

B PLUS 1 MY'S GROUND EXPOSURE )

12 C

PLUS7 DAY'SEXPOSURE}

32 C

PLUS 8 WEEK'S EXFOSURE 66 A) "PWR2" ACCIDENT RELEASE FRACTIONS TAKEN FROM W H-1400, 10 MPH WIND, D STABILITY,.01 M/SEC DEPOSITION VEL 6 CITY,150 METER EFFECTIVE RELEASE HEIGHT, WH-l@ DISPERSION COEFFICIENTS, GAUSSIAN PLlf4E MODEL.

r l

B) CLOUD SHIELDING FACTOR = 0.6.

C) GROUND SHIELDifG FACTOR = 0.2.

GHESE DOSES ARE UNCERTAIN TO AT LEAST A FACTOR OF 5 DUE TO UNCERTAINTIES IN THE " STICKINESS" 5F THE AEROSOL PARTICLES CARRYI?G RADIOACTIVITY.)

l

\\

a

-m w-

.W 91

.- TABLE VIB gd

$0 MUOR HEALTH EFFECTS FRm Itu%LATION, CLOUD SHINE, At01 DAY'S l L ExPOSuaE TO COrtrmitmD GROUfD AT 35 MILES FOLLOWIfG A PVR2 ACCIDEN i

I g.-

Ub IODIDE BLOCK!!G ASSWED)

!f:e Q.I del.AYED CANCER DEATHS )

@ TO 6 @ PER MILLION PEOPLE EXPOSE yl B

C

['.

.l g-THYROIDEFFECTS)

VIRTUALLY ALL EXPOSED CHILDREN'S AND A~

hii D

w LARGE FRACTION OF ADULTS' THYROIDS WOULD 3

DEVELDP FEDULES. A LARGE FRACTION OF b

n THYROID NODULES WOULD REQUIRE SURGICAL pg TREATMENT AND LIFETIME MEDICATION T N

br1 DEVELDPMENTAL DEFECTS

/*

MICROCEPMLY (SmLL HEADS)B)10%OFEXPOSEDF0ETUSES w

GENETIC DEFECTS

~,

PERSONSWITHIDENTIFIABLEDWINENT 91 GENETIC DEFECTS ER AN AVERKaE OF 3@ TO 30W PER MILLION PEOPLE EXPOSED,F)

C B

FIVE GENERATIONS f

y A) SEE IABLE.VB FOR DOSE COEFFICIENTS USED. THE ONE DAY GR0u AN OPTIMISTIC ESTIMATE FOR AVERAGE EVACUATION TIME.

Ei N

B) FROM.12 REM EXPOSLRE.

g F

,C)

IF THE WIND WERE BLOWItG TOWARDS EV&MTTAN, THE EXPOSED POPULATION MIGHT NWBER f 3 MIU 10N, WW.REAS IF TIE WIND WERE BLOWIfG TOWARDS STATEN ISLAND A MUCH SMALLERy N WBER OF PEOPLE WOULD BE INVOLVED.

f3 a

l R

D) 1000 REM TO ADULT, 5000 TO CHILMEN UtOER 10. tbTE TMT BECAUSE OF THE LARGE h.

NLMBER OF THYROIDS hMICH )OULD MVE TO BE REN/ED SURGICALLY, 'RE INCIDENCE 0F CANCER )OLLD NOT BE THAT HIGH.

@M E) WG-1400, TABLE VI F-9.

ri:

L'

.t

?

t.

. i, '

~

W E

r 64 DfFFERENT ISOTOPES

'y DECAYlNG WITli DIFFERENTM NN NN N fT LIFETIMES.(TELLURIUMS l:'i.

AND IODIDES ARE MAJOR RE0lON OF CLOUD SHORT-TERM r.it

~

DOSE, GROUND DOSE, CONTnlDUTORS)

.3

-e

./

LC - -

ANC INHALATION "i

g *.'f

....g

a i

.y v.;:,

idt 3

- f

r (TEC10N OF f,l

... -@l;

'i c

C L O U D D O.-

~'

I it

.*9 n'! ACTOR RADIOACTIVITY

,t$:.i r, -

STICKS TO OROUND

& g'(

BUILDINGS OFFER ?i6M.$ ' 7 'I i

. ;,3'it.N ;f.

,.3.j SOME SHIELDING f

. a., -

:'.1)

c

', !f

,J-SIDE VIEW OF RADIOACTIVE PLUME t

g, W

l i

e c

1. -f j 1 - TCP VIEW CF PEST J-RELEASE ON CLEAR NXiHT N mRECM s

C l

1 RADIOACTIVE CLOUD REGION OF DEPOSITED RADIOACTIVITY i

i O

(

WIND M 1

.x

~ ~ ' "

N %CTOR

-~

s

\\

RELEASE ON CLEAR DAY l

a m

.-7----

,,7 t

._33_

55 g

g a-pgp' sj_of k lz o

- (ot)d E CTi coTQ:

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u nT y,

ap ? a 1.su P.. 3

_\\

y.

y 1.

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'.Q g,\\p'h

.s g

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'f

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s...

f-g

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%'-(A

,a-W:

.~

a,jp s.

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4 ;

4 g

'i g,**

g gj b.s)\\

s.

• \\ ' **4.

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e,^ ' \\

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,( / p ].C.. nr

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.4 1.

.% a g, -: 5. *f y s..... '. ~ ~

.s

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e s. n n,,j..

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L.ie e4 Hg u,,

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r v3 I

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\\ %

.eA s

, ~.

.l :'. '

y y

eu s\\

pv

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p.1.c.

d,

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Fig. III MODERATE ACCIDENT

\\

g,

!I

\\ ', ig s

\\

\\

(5% Iodine Release)

UT

['.-

\\.\\

\\L <

[

DOSES TO THE THYROIDS OF CHILDREN N

\\

. 't FROM INHALATION 3'

4

'i 100 and 300 Rem Contours

• 4

.b -

l

... 4 l

c h

(Areas in wh1ch Dose Equals or

\\gti*

92 i <j Exceeds Stated Values.)

?

\\

\\

.c.

e3

--.\\\\

m *.

.s - s s - s s

~

e g

. 8 8

' gro

.y0 R K (Ot)AECTI CU' t

8 N

.g.$ J J:.

Pa. f

\\

s,

,e r,,

m s

s.

~

s l@0 Q q T a,M 6'i 7

^

s

. g;..,

-V.,

e-a g e sey '*"%

• /

(

ggse * &O

%.i.e.,

.s; FE O

_ yp k l p.1. c.

'b

~

• (

s, \\

j i

si %'\\

\\

N

~

y p.u.

Y' \\

Fig, IV PWR2 ACCIDENT l

\\*

//"'.b*\\

Q

\\

1 DOSES TO THE THYROIDS OF CHILDREN l

,\\

• h

\\;'

FROM INHALATION 1500 and 5000 Rem contours (Areas in which Dose Equals or

\\

hJ d

Exceeds Stated Values.)

1

.... 3

~

~

• s g

.s MkU

\\/O d IC l

(Cl)SEC*il c.o]

\\

Zal:.. Po..d

\\

q, 9

i j'

,1

,t a

s v

~.

\\

l [ !l

~

s.

, N

~

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g h

'd s-s d

2 Te%'"

N s '.,

m

.N O50 Y

f p.1.c..N Qlik:-

3b agesey Li"Q

]s,0 a3 v...y.

b7 N\\

p.Y. c.

l p.1.c.

a

-~

\\,

's \\.; \\

Fig. V PWR2 ACCIDENT f

s s.

\\*

'\\

EXTERNAL GROUND DOSE FROM 1 DAY'S EXPOSURE

\\

\\

(Areas in which Dese Equals or-t l

\\

Exceeds Stated Values.)

... _ __...._..... _....._ 1 "

• '~

..e g

,.-34 u-

, /0 8 K N6'M

\\

t (Cl)AECTl C 0) y 2,J:.. Pe. I

\\-

()

\\

}f9 p\\\\.

1

\\..

i }

l

/

T s

~_

t

.y f-3 d

h T#%

$1'*..,

V, f.m E "

t (s ***h l,

~

p,Y. C.

v' 7

\\ \\. T. \\ \\ \\ ~\\ \\'s \\\\

i

.(

i p.'.f.C.

\\,

v.\\\\f

.K Fig. VI PWR2 ACCIDENT s

t

\\ 's N EXTERNAL GROUND DOSE FROM

'g

\\i 7 DAY'S EXPOSURE l

s 5

-\\

(Areas in which Dose Equals or

\\\\

' Exceeds Stated Values.)

'\\'N K

j

.\\ \\\\\\\\\\\\\\\\\\. \\h\\\\

\\

I.

~ ~

L

~

• t g

'g hkN

,y0 N K (Cl)NECTI cui I

.\\

f 1 J:.. Pa.J

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g:

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T N

A s.

,N Aj R g

a w

q %.

lx sem-s

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f 8,*

s

+

b$

4 p.(.G. 9 l

~I e

hk gh

[

3s.,J o

L"Q

/

Y ' '** '

l P Y C i

?.

Fig. VII PWR2 ACCIDENT LONG-TERM LAND CONTAMINATION CONTOURS

\\.

[-

\\

\\

\\

(Areas in which 30 year External Dose

'\\\\

from Cesium would Equal or Exceed

\\

\\

\\

Stated Values.)

The inner :sntour (150 t c:) would be highly contaminated with perhaps a a

l

5.r

-as-

~

58798.#"

.. HOTICIS l

[4]jo.gs.;4}'..

- verse effects from einosure to rad!. blocking purposes under certain emer-

. muon in the event that radioactivity is rency conditions.

The report dheusses stockptiing thy-

' DEPARTMENT OF HEALTH, released into the environment. nese.rold-blocking asents at appropriate

~

plans am to include the prophylactic EDUC/J1ON, AND WELFARE outlets for ease of distribution la the

$-' ' use of drugs that would reduce the ra.

event theft use is necessary in a radt-diation dose to specific organz due to r d d D.w H " S r the sudden release into the environ. allon emergency. The. report con-

. CDocket No.TED-os41 ment of large quantitles of radioactiv. cludes, however, that the detalls of

~

Potastrum ICDiot AI A TMYRQt3 stOCYJN4 117 that En!ght include several radioac. Stockpuing if this method is to be ActNT IN A aADiatioN Extaosucy t2ve isotopes of todbe.

used, and of distribution would be de-termined best at the State and local levels..

BACEcaoCND a.,..a t., s u.i :eae of New Dmg ApeGa.-

M **d "*** A'*"W d

• The SA notice of December 24 ANArrsts l d d that there la an ex-

• AGENCY Food and Drug ANS -n.

1975, conc u eL.ceedingly low probabluty that inct.

The Commissioner of-Food and Drugs has analyzed the NCRP report e- - dents win occur involving either the tun.

and the avanable scientific litera1ure.

use of radioactive materials in fixed about the possible prophylactic use of -

. ACTION: Notice.

nuclear f acilities or the transportation drugs to reduce the radiation dose to SU?CdART The Food and Drug Ad.

of those materials. Because of the pos-ministrauon (FDA) requesta submis. sible increase in number of. nuclear the thyroid gland in a radiation e=er-

' slons of new drug appucations (NDA's) power plants, however, several Federal sency. Alth.ough a variety of chemical for potassium todide in oral dosage. agencies are identifying those posat. substances can block the accumulation,

of radiolodine in the thyrcid gland.

forms for use as a thyroid-blocking buities. however remote, that could i todide in the form of potassium iodide asent in a radiation emergency. The adversely affect the public, abould an appears to be z=ost suitable for this coproval of oral dosage forms of pota.s-incident occur. One possibufty is the alum todide as a thyrold. blocking sudden release of large quanuties of purpose. A number of factora.wers considered in choosing lodide (and spe-egent for use in a radladon emergenc3 radionuclides, wh!ch might include a cifically potaaslum lodide) over other would be one step in meeting the re

• number ofisotopes of rad!olodine.Into blocking agents such as propylth!oura-spon!1bultiet, of the Departme.nt of the environment. When rad!olodines CE D'

" I' P'#8AIO#8E# Ehl0*

• HesRh. L!ucatlom and. Welfare are inhaled or ingested, they rapidly cyanate. or todat'e. These fact' ors in-(DEEW) to State and local govern-accumulate in the thyrold gland and cluded the degree of the blocking rnenta for radiological emergercy re-

• are metabolized into organic iodine scNmd. me rapidty on onset of M sponse planning. The agency encour* compounds. These compounds could bl6 eht, h durauon of me tres interested persons to sub=lt reside in the thyroid gland long blocking effect, and the safety of the NDA's in the interest of the puhuc. enough to anow for local radiation blocking agent. Although iodide acts I

safety. The agency is also announcing damage, resuRing h thyroidus, hy.

on Wd gland in smral ways.

the avalishutty of labeling guidelines pothyroidism, or thyrold neoplasia Its use in mia batance is W.maruy for potassium lodde for such u e..

with eltber benign or malignant char. predicated on its abulty to saturate

• ADDRESS: Submit new drug aps.lica. acteristics. 'I'herefore, it is conside:ed the lodde transport system, and thus -

cons to the Food and Drug Admiets. in the public interest that State and effectively aboush entry of rsdiolodine tration. Division of Metabolism an3 local authorttles be prepared to take except for small amounts that sn!rht Indocrine

• Drug Products (HFD-130), effect!ve measures to prevent or cut - enter the gland by diffusion. Ai=ost Rm.14304. 5600 nshers Lane Rock. tail markedly the accumulation of ra* co'nplete (snater than 90 percent) viUe. MD 20857. Comments concerning eMiodines by the thyroid gland, blocking of peak radioactive iodine l

the labeling guideline and requests for shc. tid such 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 a tained by the oral *N tistration or to the Hearing Clerk (EFA-305). Food thyroid. blocking agent.

100 mil!! grams (ms) of lodide (130 mg

• l and-Drug Administration. Rm. 4-65

. An ad hoc committee to the National of potassium iodide) Just before or at 5600 Fishers Lane. Rockvine. MD Council on Radiation Protection and the time of ":.posure. A smaller dose 3,,,..

Measurements (NCRP), which includ-gas

. w potassium lodde) can be 20857..

FDA npnsentatives as consuRanu, used in infants under 1 year of age. A

. FOR FURTHER - INFORMATION-studied h feasibuRy of using certain daDy dose is required to maintain the CONTACT **

n*

drug products as thyrold. blocking blocked state. The use of a blocking Edwin V. Dutra.

Jr.,, Bur.au of agents to reduce radiation dose to the agent is not expected to exceed about ~ -

Drugs (HTD-30), vood and Drug Ad-thyroid gland. The NCRP located in 10 days.

ministration. Department of HesRh. Bethesda, Maryland is a nonprofit Experiments designed to study the Education and Welfare 5600 Fish-corporstion chartered by Congress in rapidity of onset of blocking have l

l ers Lane. Rockville. MD 20857,301-1964 to conect, analyze, develop, and shown that at a 100.mg dose of todide.

1 j

443-6490.

dirseminate informauen and recom* the omet of blocking is readily demon-J SUPPLEMENTARY INFORMATION: mendations about radiation protec* strated 30 minutes s.fter oral amtis.

i tion. The NCRP is made up cf 56 scl* tration. The decay of the blocking By Trnzzu. Rrcts rx notice of D-cem.

bar 24.1975 (40 FR 59494). the Gener. entific committees. cor posed of ex.

effect after cessation of todide admin-al Services Administration (CSA) out. perts having detailed knowledge and istration is relatively slow, so that a a

lined the responstbnities of several competence In the particular area of dauy dose of 100 ::: of todde (130 mg Federal agencies concerning certain the committeers interest. An NCRP of potassium lodide) appears to main.

er:ergency response planning guld. report published August 1,

1977 tain effective blocking. To have the l

l

, NCRP Report No. 55. " Protection of greatest effect in decreasing the secu.

(

ante that the agencies should provide to State and local autherttles. The De.

the Thyroid Gland in the Event of Re-mulation of radiolodine in the thyroid I

partrnent of Health. Education and lease of Radiolodine**) discusses the gland, the thyroid. blocking stent Weifare (DHEW)is responsible for as. ' safety and efficacy of thyroid blocking shou!d be ad=inistered 1:==eciate!y i

sisung State and local autherttles in agents and recomrnends that pott > befc e or after initis.1 exposure. A sub.

l develop!ng plans for preventing ad-alum iodde be cons!dered for thyroid-stantial benefit (e.g., a block of 50 p-r.

j

.sg. _

,~_y.

pe_&.,,..3 $uWWo, 9

e--

2

\\

i 58i99 I

d

~

9.-l.[...'-

NOTicts c

ya.

t,bla f:r CYIC sale does not affect th?

O ent) is atta!nabl2. howmr. whrn the

".., Cosect.trazozes - *-

presen a a us as a prescriptbn dmg l

..ccking agent is first stven within 3 g Commlutoner concludes that ap ass um lo de dmg product c4 ( hocrs m.fter acute e.xposure. If a potassium lodide is safe and effective

• • ""I"# ""

'# "*** Of 'E

-r 'on is exposed to radfotodine when for use as a thyroid blocking agent in

[

higher dosages.

trcumstances do not permit the 1m.. a radjation emergency under certain The Immance to h puhue of nediato aMMetration of potasslum. specified conditions of use because it sdidt, the initial me*mf*tration will has been widely used for many years, h.*"

E[

'M I

se of sogne um! Led benefit even as long in large doses, and on a long term will be needed retsforce the Cocums.

s 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a.f ter exposure.

basis with an inchience of side effecta aloners Mef mat ph;um lodde as Although most of the rad!olodine and toxicities. in general, proportional a thyroid-blocking agent b a radation hat Ls not taken up by the thyroid directly to dose and duration of ther.

-!and Ls excreted in the urine with!n spy. The riska from 'the short. term use j'y'h"hD Co i

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the radoiodine that is taken of relatively low doses of potuslu=s g gg g

4p by, and accumuhted in, the thy. lodide in a rad!ation emergency are d

ta p en us co =

g o d ritad psay be " leaked" haqk into outweighed by the risks involved from he general circulation system as a exposure to radlolodine. However, the l

otisequsace of intrathyroldal metabo. Commissioner does not believe that 3=. Thus, there is a possib!11ty that potasstum lodide has been used to safely and effectively-A labeling treulating and recirculating radiolo. such an extent or for a period of t formation to be included on the coo.*

fine may be taken up by the thyroid

," conc on that the d.us is tainer label. If space permits, and If g

land (from the circulatory system) genera.uy recornised as safe and effee.. the accompanying labeling is on fue ven thcush there are no radiolodines tive. Accordingly, it is ngarded as a with the Hearing Clerk. FDA. The cmaining in the environment. To pre. new drug requiring an approved new guideline sets forth specific language ent cr curta11 the accumulation of ra. drug appUcation as a condition of mar. that would be acceptable to the liciodins by the thyroid gland from keting. Thus, the Commissioner will agency.

My source. Including chron!c expo" accept new drug applications meeting The guideline is ent!tled "Ouldeline ure, a daily dose of a thyrold-blocking the requirements of $ 314.1 (21 CPR I.abeling for Potassium Iodide for Use' gent is necessary for a period of time 314.1). Because 3f the publicly avana, as a Thyrold Blocking Agent in a Ra.

Iter exposure. The durat!on of time ble safety and elficacy data document. dlation Emergency "

hat a btxking agent would be re- *ing the drug's u.se, the safety and efft.

Theeperson responsible for mfa*.

o uired is not expected to exceed about cacy regulrements of f 314.1 may be ic t the4uideline label!ng is JoAnne C.

O days. A minbsum of 3 to 7 days of met by citing the pubushed Uterature Earrone. Food and Drug Amstra.

g-ally administrstion is anticipated in the Lbt of Material Consulted tion. Division of Metabolism and E:s.

I.

assd on the biological events de-(below) documenting its use. The docrine Drug Products (HFD-1301

[

ribed above and the eff ective half. Commissioner advises that it is unnec. Room 14B04. 5600 Fishers Lane, Rock.

essary to submit (1) copies and re. viUe. MD 20857, 301-H3-35:0. Copies f

Je of uit

~..

Potsasium tod!de 'his 'been used printa of the data cited in the List of of the guideline are avaUmble from the 1dely for many years in the treat,.

Materiar Consulted in this document. Hearing Clerk (address above).

1. *" N u o o

rs. D y r d e

i1

! potaasium lodide ranging from 300 CFR 310.9). Both the safety and effi. -

t. Adams. C. A. and J. A. Bonnen. " Admin.

cacy data upon wb1ch the Ccmmis, titnuon of stable lodide as a Means of Re.

o 1200 mr have been given to asthma.

stoner bases the above conclusions and duetne Thyroid Isradiation resu.Iting trons ics over long periods of time. Daily NCRP Report No. 55* " Protection of Isha2auon of Ramoscun locne. Recm tal dosss of potassium lodide of 100 Payrtes. t127-149.1962.

4 or greater have been administered lease of Radiolodne the Event of Re-

2. Blum. M. and M. E.senbud. " Reduction are on fue for of Thyroid Irra.diation from 1311 by Potaa.

I " -

a cough preparations to children. Al*

pubUc inspection in the office of the alum lodJde. Jonaz of rAe Amencon medi.

hough a variety of adverse reactions Hearing Clerk. Food and Drug Admin. est Assoesattos. 200:103s-1040.1M7.

inve been reported in connection witla 1strat.lon. The Commissioner invites

3. Ramsden. D. F. E. Passant. C. O. Pes-

't he use of potassium todide, these re-appUcanta to submit any other perti.. body, and R. G. Speleht. "Radiotodine Up.

etions are considered. in general, to nent studies and hterature of which takes in the Thyrvid studies of the Block.

I

. Ins an# Subsequent Recovery of the Oland e directly proportional to the done they are aware.

this specific use of potassium todide., $Mg,$ p$g376$4s.19 The Commfuloner also beUeves for nd duration of therapy. and most j

4. Johroon. A. E. "Ibe Rate of Return of I

oticity has been related to chronte dministration (see pp. 38357-38358 of and at the dosages intended, that the Radiciodine Uptste by the Nor:nal Thyroid t 4 he !!ndings of the Advisory Review prescription dispensing requirements After Suop*casion by Pharmacolosical

'snel en Over the. Counter (OTC) of section 503(bx1) (21 U.S.C.

Domes of stable to&ne." Nese PAynca

old. Cough. Allergy. Bronchodilator 353(b)(1H of the Federal Food. Drug.

858?,,448.19s2.

p s Ra o Ra i 3

ad Ant! asthmatic Drug Products. and Cosmetic Act are unnecessary. u g % bio,lo g

eublishtd in the Fus2M. Rtctstut of Only the chronic administratten of search Council 20 Psra Crescent. London.

h daily doses of potassium iodide far in

s. Cronauis. A E. E. Pochtn. and B. D.

eptembar 9.1976 (41 FR 38313)). In exceas of those necessary for thyroid. Thomsson. "The speed of Suporession by

.1dvlon to its use in pulmonary disor.

c n a radiation e m rgency ledate of Thyroid Iom Uptake. Neam

- te r, potassium lodide is used in da.ly have resulted in significant side effecta PA rnes. 21:393 394,1371.

l loses rsnging frecs 250 to 300 me in and toxicities. These problems should t D*m.1. A G. V. Artdynreratara. Tu.

ntients for up to 3 week.s in connec* not occur from the short-term ttse of &

O. Konstantinov. and L A. Latatarev. "Ra.

ton with the diagnostic use of radio. relatively low daily dose of potaasiu:a comeun lod ne in the Promm of Raci.

Ices '

suon Safar. Trsastauon senes. USArc -

-g iharmaceuties! drug products ta block fodide. However, the Commissioner ad.

he uptake of tsdiolodine by the thy

• vises that the conclusion that a pets.

"38["3, I"$',*u" n 'of '

l D

g, oid gls.nd. The Commissioner is un.

stum lodide drug product manufac. from Fattout: Ham. ares and Counter Mess-Eare of report.s of significant tax.lcit" tured for use as a thyroid blocking urea." Contract No. D ANC:o.7o-C-o3st. De,

.ith this use of potassium lodide, agent in a radiation emergency is suit. tense Civil Preparedness Asener. Otisce of FactaAL etCasTle, VOL. 43. 800. Set--Pt10AY DtC2/4see 15. lpe o yo yw w ML O

l 4}5300.

E. E. et af. "fW Zrra.ta.

persons to submit written mmmee. ' )...;

w r,.,w ry' ol Datsummn. washfasaan.DC.. *.11. Ma *e.atsaa ans i.be InductJoo of Casam117 s'ss:n-tor,Iershly fr.tr copies. spec.fri..s.I f

.eant o ma na use uu. man Thirud ota.ed."

Estring Cled.M.t no.1&n 430) en 'I ett a sa,se r.. u. es at, -wwm=> Damme,

+ roeds Recurrws to samrr UptaAe or v.erscan Jomrmal W xadictea, sa.ss1.s4. the E.ddeline tabding to the % tag

• t 14.P="-"+^ wa'ad Thrtold Cartino.. C!ert (EFA.305). Food and IW,g Ad...,

1877.

4me.121 by Norrmal Threo.d.- sesenau, '

ni=1s'.rstio=. R=:. 4-45, 6600 Mahars.,,

i tee 3C,.421.1 M 2.

o. vasen. m A. o. et at. -toede In-ma. EA:ad by Z. J. DeGroot wit.h I. A.

l

.uced Thirotc.zicos a in Boar.cm." New Kne.

Prohm an F 1. I:aptan, and S. Refetaff.

IM.e. RockvfUS. MD 20837. If. as &

~'

i cad Jaarmal at wed csaa.1sts:3-427.1872. Oro.ne and strattoe. Inc. pubusbers. IrTT.

result of com:sents recetved cs the I

i1.-Reactor safety study. An W"acet J27. Isogen. ann. F. w. and J. c. Thoenp. '.guldeline tabellar, the Co:n=1saloner I asvi. Jr, Prophytactic and Thersoeut.se dete. ines that the tabeling thould be ~.

.t Aects2rts al.nas an U.'t. corse:ertta2 7tucie-

.c f*ower Pia =ta. Appefwrz VI. Calculauces Mansures for Radiow se Can' ~ w= " ' revised. a notice irill te E"blished in 8 Reactce AceWnt. Consentrances.

U.S.

ReaJL4 Mpasca F.1031-1331.1M1.

the Pz:m P.mt m sn=o =s:bg tr.st, 4uclear Rer c tory comcualon. Report tz. Pec.bla. E. I. a.od c F. Bar.abt. -T'.e smh ch2.".ges have bee: made.

t! A3)bleCo. NURIG-15/0 t 4 t12131.

v r. gect og pt.gn.,aco'.occal pen.s og Non.,la.

The CC:.=!saloner ha2 deter =1ned

12. N L.:4tnal twn ca Raist.1on Protac. dJoacure lodido en the Course of Raconc,.

on Repc:s No.1s. -Protecuan at the Thr. e:n, catar, er the Thyrold. 3rs :4 Mrs.

that this does. ment does not contais

~

' an scener setten covered by f 23.lth)

Sofodirn." NaconaJ CoordJ on Radiattaa

19. Canard. R. A. et al, "A Tumty Test ~.(21 CTR 25.1(b)) and, therefore. eco. i --

old clasd ts the twent of ReJesses or Ra-gem, T-2:5 125. !M2.

Protect:c.o and Measurements. August 1.

Re.vte., of Med;ca) 7bdinrz t: a Marshal.. siderat.los by the agency of the cred ', 8

)

less Popu:Ar. ion areHectally Erponed to Ra.

BNL 50424.. @r pre; art r an stroe.o-sta!

t977*

1=P2ct state:nent ns not required.

12 Omeral Services AdrMnktratJon Fan.. concuve Fallou t."

Re:ert

< ass. Ractatra coa,ca. M FR SMM. Decem>

Brcet. haven Nauccal IAboratory.. Uptcc.,

'* ?

1. I

.e IN

--+-r 3.1978..

a N T.t315 it. Talbot. J. M E. D.. Fisher, and C J.

2n. Goodman. I. E. and A. G:.sas, n, q Dated:

>rr 24. IM1.

d carr. -A nrnew at the strear.cmace at Un.

paa,,u.,,.3:cc,o 3,o c/ n <n sprutics. <

. ~..,. -don 41.D KZ2 ore 3Y.

,a Lew mid Re actions te locne in Poods.". Sth Ed. MacMinan Pubilshhtr Co.,1.nr

.'.." Commia2iontf C.fIced cut.Druga.

Rtoort af the Peders.Uon of Azmencan Soci..New Tort. pn 401,302,1975.-

... s -.

u tues for Expert:nantal Biolccy under FDA

.'I'ha. ssency encourssed laterested. [FR Doc.TS-34M3 Filed 12-147t: 3:44 ass)..'......,f

'.,..'; g.,.

contract Nu.:nber 112x. septan:bar tria.

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39-I Studies of Nuclear Accidents by Jan Beyea The Effects of Releases to the Atmosehere of Radioactivity from Hypothetical LarRe-Scale Accidents at the Proposed Gorleben Waste Treat =ent Facility, report to the Government of Lower Saxony, Federal Republic of Germany, 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, September 1,1978.

A Study of Some of the Consequences of Hypothetieni Reactor Accidents at Barseb*a'ck, report to the Swedish Energy Commission, DS I 1978:5 Industri-departmentet Energikommissionen, Stockholm,1978.

(Also printed as Princeton University Center for Environmental Studies Report #61.)

Program BADAC, Short-term Doses Following a Hypothetical Core Melt-dow1;,

computer code written for the New Jersey Depart =ent of Environmental Protection, 1978.

Consequences of Catastrophic Accidents at Jamesport. Written testimony and cross-examination before the New York State Board on Electric Generation Siting and the Environment in the matter of Long Island Lighting Company (Jamesport Nuclear Power Station, Units 1 and 2), May 1977.

Emergency Planning for a Catastrophic Reactor Accidert, Invited testimony before the California Energy Resources and Development Commission, Eme gency Response and Evacuation Plans Hearings, November 4,1976, p.171..

Short-term Effects of Catastrophic Accidents on Communities Surrounding the I

Sundesert Nuclear Installation. Invited testimony before the California l

Energy Resources and Development Commission, and cross-examination et same, i

December 3rd, 1976.

The Sundesert hearings were the first held under the new l

California siting law.

Consequences of a Catastrophic React.or Accident, Statement to the New York City Board of Health concerning cocaequences of an accident at Indian Point, August 12,1976, (with Frank von Hippel)t Comments on WASH-1400, Statement to the Congressional Subcoc=ittee on Energy l

and the Environment. Oversight hearings on Reactor Safety, June 11, 1976, Serial No. 94-61, page 210.

Uoner Limit Calculations of Deaths. From Nuclear ' Reactors, J. Beyea, Bul'l.

l Am. Phys. Soc.j[L, 111 (1976).

t 6

q r

4 p

s wm awPR5Dl4 m Wib) m6m>c u e

rme w h..

• T* M.

k CC*?": TIS CT TEZ CNION CF CCNCE*3t3 g

i SC:Z:rTIS~S C!I Ct!P.GCfCY F1ANNINC.

constitments but no genuine review - is thus ST2ately in the a.a fil A.RCCM3 NUCLEAR TACILITIES N

tr

~

%]

tradition of avoiding the issues which arise f rm t?e I) 3 On July 17, 1979, the NRC published an advance netice possibility of a serious seeident such as a cere moltdewn.

of preposed r-slenaking en the adetsacy and acceptsace of we say this not sireply to chide tre Ceccission for past b

emerg.ney planning around nuclear facilities. 44 fed. Reg.

negligence but to point out that it must actnewledge that C9 41483. The notice informed the public that NRC is consi-the crucial lesson of TMI is that serious accidents can 5

A 5 <

dering adopting regulations which will establish as a harran. It is a simple proposition, but its acceptance by

{]

f condition of licensing that apolicants demonstrate a higher the NRC would begin to work a revolution in regulatory level of preparedness to take action to protect the public philosophy.

In' fact, this proposed rulemating represents So too.

acknowledgement that such accidents can happen.

in the event of a serious reactor accident.

Bef ore addressing ourselves to the specific questions albeit in an equally tacit fashion, does the staff's policy bd posed in the notice, UCS will off er seme general observatiens.

en rejecting sites with population densities out to 40 miles The AEC and then NRC's failure to adept serious requirements above certain

• trip levels.' After all, such populations are only at risk if one assumes the occurrence of a serious for evacuation planning and other pretective measures or to y

(Class 9) accident.

tie these requiramants to licensing, stems directly and

~

newever, the Ceessission needs to affirnatively wipe inexorably frem the agency's refusal to face forthrightly out the vestiges cf a fatally flawed regulatory policy and the possibility of a major reactor accident which weuld require the consideration of serious accidents in al_1, aspects result in radiation doses of fsite. It has been a historical f

of licensing. The discredited " proposed

• Annex to 10 CTR hallmark cf U.S. nuclear regulatory philosophy to deny the 5

Part 50, excluding Class 9 consequences from NEPA raview g

The consequences credibility of a so-called Class 9 event.

should be immediately withdrawn. The present system is

(,

of a majer accident are systematically excluded from impact logically and philosophically inconsistent as well rationally

, 1 M

statements prepared pursuant to the National Environments 1 j

insupportable.

In like fashion, Class 9 accidents are not Fina11y, emergency planning issues are tied closely to 0;

Policy Act.

considered es ' design basis events' and no measures are There are presently seme eversting reactor

'UI, siting policy.

The NRC's ambivalent required to mitigate their effect.

sites where the number and concenerstion of surrounding attitude toward emergency planning - requiring lip-service pcpulation nake it a pesetical impossibility to take protective a

e g$

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3 measures. No one yet knows how many och sites exist, but certainly Indian Point, near New York City and Sica, near objective would totally undermine public confidence in the Chicago, present essentially intractable problems. All safety of the population living near reactors.

operatin7 reactors should be reviewed on a priority basis reasible implementation of emergency plans must be a to deternine for how many the envircus are unevacuable as prerequisite for siting approval for new reactors in order a practical matter. These should not be per:mitted to to insure public safety. Where existing reactors cannot operate. In addition, future siting should be restricted meet feasible implementable emergency.*ans to provide for to areas truly remote from population. This would be a public safety in event of a core meltdown, licenses should be revoked until such time as an implementable emergency major step forward in learning the T2tI lessons.

The remainder of UCS's comments will address the specific plan has been demonstrated.

oorstros:

questions posed la the published notice, (2) What constitutes an effective emergency respcase Qtristics:

(1) What should be the basic objectives of emergency plan for State and local agencies? For licensees 7 What are the essential elements that must be included in an planning?

w effective plan? Do existing ItRC requirements for licensees L

(a) To reduce public radiation (10 CFR Part 50, Appendix E) and guidance for States (NURIG-k exposure?

75/111) lack any of these essential elements?

(b) To prevent public radiation ANSWER:

exposure?

An effective emergency response plan must be tested and (c) To be able to evacuate the public?

proven implementable 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 Mswta 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.

a danger to public health exists and to implement protective lity. It would be irresponsible to qualify or ccmpromise on

-mn.

m s as, e co - s.. sa m iac m, in ~ m case.

aE m s ob3e m.e.

r o e _ e. an, sua1 m ca m n of m.

n h==

~

c=

5-

.s.

The Governcr, who had tha authority, did not have access to 4 W anes and ships.

accurate inforzation, at least within the critical time Present NRO practice is totally inadequate, although Mriods.

I "* **

"I State goverr.monts should either employ or ccatract

=

"~

"i appropriate local residant specialists in nuclear physics,

'#* **** ~ **

nuclear engineering, chemistry and biology giving them,

^

responsibility for regular inspection and crisis intsrvention which charges them with making declaration of a pending public 1) it does not require any detailed implementa-eafety emergency almultaneously*to the Licensce, chief elected tion plans at either the construction pemit or operating license stages, official or local and regional governments within a 50 mile 2) it does not require any testing or actual radius and the press.

field verification. Essentially, it requires only paper, and vague paper at

- The U.S. Erd process for emergency medical care coupled

that, with the of ficial health planning agencies for states and 3) it contains no performance criteria whatever against which this paper can be ju2ged, their sab-state regions should bear the responsibility for W

4) this is compounded by the f act that there is 1

assessing the plan's feasibility of meeting emergency response no guidance offered to the agencies charge,:

m with the responsibility to take protective w

from a health perspective, action on what the health and safety conse-The transportation systass must have adequate capacity

~

quences could be of the range of potential accidents. Thus, the Governor of Pennsylvania had to ask the Cce::aissioners in the middle of to acccmodate the number of people evacuating because of a

(

}

the T:(1 accident what the consequences of exposure could be and was told by the Chairman public health safety hasard in the effected area within a

(

Q that there is no good information on the sub-ject! Meanwhile, of course, the plume had set period of tine (6 hrs). Judgment pa this aspect of an I

already passed, e.nergency response plan can best be made through the process 5) it does not specify that the " design basis

• g 3

for emergency planning should be a Class 9 U.S. DCT uses to approve transportation development projects, d

J accident, or provide parameters for evaluating the range of potential releases. Therefore, Significant federal planning resources already enable each the areas covered are "ar too small.

of the nation's 'MPO's* (metropolitan planning organitations CtTESTION :

of chief elected local and state cfficials) to know their O) Should NRC concurrence in the associated State and capacity limitations for road vehicles, rail vehicles, local emergency response plans be a requirement for continued operation of any nuclear power plant with an existing opera-u

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ting license? If so, when should this general requirement beccos effectiver urswcR power plant? If so, when shculd this ger.eral requirerent s come effective?

Yes.

Prior NEO concurrence, ccncurrence of the MISWER s governor (s), the chief elected local of ficials within $3 miles of the site, and the cencurrence of elected legisla-Yee = inzodiately. And a much more detailed shcwing ture efficials (local, state and federal) for the ease gsegraphic arsa shculd be required en emergency plans for priate protective action in the event of a Class 9 accident should be a prerequisite for a construction permit. Na more public safety and evacuation. This concurrence must be a satter of public record and official sign of f should take Seabrooks should be permitted, with the NRC officially place subsequent to a acoth 1cng period of local distribu-blinding LLself to the existence of thousands of pecple just tion of public education materials coupled with a drill on outside the LPs on the beach several miles from the plant.

If TPtI had happended et Seatrook in July, the evacuation said emergency plan.

even of women and children within 5 miles would have produced The requirement should be immediately effective for existing plants in an area where population within a 50 mile radius exceds 1,000,000 people. Other plants in (5) Should financial assistance be provided to State sparsely populated areas should have a deadline of 6 W1 sMruh@lwmmp mcnths to operate prior to plan approval.

-y planning and preparedness? If so, to what extent and by NRC must find, as to each operating plant, that the g

g af fected public can be protected in the event of a Class 9 accident. There are a number of operating reactors for M

Absolutely. The level of funding required should be which this is clearly not the case. Indian Point and Zion derived from national standards to be met set by NRC 3

j l

are two obvicus ones. These plants are a real threat to 8R r

M9 together with arw and DOT.

The licensee should be obligated public safsty.

I 6

to pay the municipality, any af fected regional government, f'" M ocesTIcus

..J and the state (each in separate transactions > soi of this t

i ' 'a 1

c=

(4) Should prior : tac ccncurrence in the asscciated m[, "i funding annually from the filing of an application for a state and local energency response plans be a requirement y

A f

a

'y 7

y 1

- - - - - ~

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License until said plant has been decanaisaloned long enough to present no further potential public health State and local civil defense agencias should assume and safety risk, The local, regional or state government the lead with pecper training frca the N30 as closely w uld annually apprcpriate the other 5H.

Should any monitored by the state's coensittee of technical experts l

cf these governments in any year f all to appropriate described in the answer to question (2) above. At least I

their share the licenses should be obligated to shut cae driti should be held before the pub 1Lo and their i

down until such appropriatica is r.ade*

officials sign off approval on implementability of the l

[>

C' tsTices a plan.

(6) should radiological emergent;y response drills be outstro:e l

a requiremest? If so, under whose authority: Federal, (7) Ecw and to what extent should the public informed.

State or 1ccal government? To what aztent should Federal, prior to any emergency, concerning emergency actions it State, and local goverr.sents, and licensees be required to alght be called upon to take7 participate 7 uswras usurp s The CAO investigation cited above tcund that the only w

e Yes.

CAG concluded in its recent report to Congress efforts at informing the public about possible emergency C"0 gf cn this subject,- after site visits to eleven nuclear action were pubite meetings called by utilities during the 3/

facilities and analysis of quesionnaires to all states, licensing process - years before actual operation.-

g that usteated plans *would probably be iseffective is as further actions were taken to inform the public. CCS emergency situation.' U Thus, as untasted plaa is worse wh believes this failure to be little short of scandalous.

than nothing at alls it provides a falso sense of security (C)

CAO stated:

and lulls people into complacency.

racility operators did not appear cencerned C

about the lack of informatica made available to M

the public. This reflects the attitude of most operators, namely, that there is little danger 1/

• Sites Arcund Nuclear Facilities should Be Better Prepared to the public from their facilities. This attitude for Radioicgical f:mergencies,* cc.78-110, March 30,1973.

f was surmarized by one operator who said that he did not expect serious accidents requiring large-scale public involvement to occur and that prompt 2f Ed. p. 11.

v Jf' H. at 28-31.

aEE3 s

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-LL. notification and normal local offsite emergency response actions would receive total public ccepremising on a 'tess severe Class 9 accident.* There cooperation if a nuclear e: ergency did occur.

In sost cases, the operator's confidence of the Joint Task Force, with this important change, in public cooperation has not been put to the test, even om a limited scale, to determine its sight usefully serve as the focus of the rulemaking pro-validity.

There can be little gaestien that the public needs to caeding. Bowever, that should not be permitted to serve know what to do in the event of an emergency. This requires, as a wedge for prolonging Commission inaction. It should act immediately to require licensees to have unc concurrence the distribution of inforsation, by mail, updated annually, to at least the present requirements, to all persons living within 53 miles of a plant, of proce-OutSTION dures for evacuation, the location of evacuee centers, the (9) How and to what eatent should the concerns of location of medical facilities, etc.

In addition, the state and local governments be incorporated into redersi utility should be ensponsihte for arranging widely-advertised radiological emergency response planning?

public oeotings in each af fected city or town to bring ANSWER:

together the responsible officials and the public, to review w

.It le irresponsible not to heed state and local concerns 8

the estergency plans.

as, in the last analysis, they are the people who are most CUTSTIONs impacted by the accident - living with it, and recovering (8) What actions should to taken in response to the from it.

They are in a position to turn any theoretical recommendations of the joint ttRC/ IPA Task Force Reporg emergency respcasa planning into a workable reality. In (NURIG-0396/ EPA $20/1-78-01637 addition to all the co:mnants in other responses to these o

questions concerning their role, it is critical that on Ansuras The Joint Task Force Report represents a significant b

)

an ongoing basis state, 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 encagh. There is insufficient justifi-re cnh w th federal ometals as wen as data cation for limiting the Cnergency Planning Zones for plume

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and other information heretofore considered proprietary.

exposure to 10 miles. As indicated above, we support the A8 a practical matter, the involvement of numerous use of a Class 9 accident as a planning basis for energency eve a q vernment in t is situation tenda to nesta

]

action. The Task Force fadges badly on this, apparently l

confusion, diffuse responsibility, and weakenei accountabi-25ED b

f j

e i.

k toc:I! acm lity. The only effective way to knit together the whole PW l

as is for one organization to asse supervision, and the

,a seaee e, an u.

e, caly effective wedge is the interest of the licensee in es>aar,=aar es =4tw.6 euev cas o

costicaed operation of his plant. Therefore, the super.

a aec a.es s.sr.6 so.e se=. ses.te.

ca ta a

r,t eursa =o vision has to be la II1tc, which can enforce it.

eme =.

Under leaC's review, licassees should at least annually

'"4"'t 29.1979 contact each responsible state and local otticial, make suretary of ne wastos eure that he/she understands and concurs la his/her role 6 et Commise e

DC la the event of an emergency and solicit comments on the

• Q gg, 34,,,,,3,gg,,,g p,,,,,,4 need. 'if any, for changes.

-9 gp O$1S ? k, Beetmaking "Adequac y and acceptase of Emerzeur Flanalag Aresad seclear Facilittu*

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corned

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(rm sa: 138 Teesday.

acientiste y

sely ip, ggy,g)

Seer nr. Chilka Y

J I EllYtL,,A. ideiss It appears from the superf tetal nature of the 9.esttens la the sebject w

03' General Ccuasel rederal Register eecise that the RC is sec yet familiar with the real world prehtsas inharset is pub 11e planales for energeactes at nuclear power plaats.

N Celertaattely, most state and local civil def eece coordinators, who are very f atallar with their local sitaattaas, are set yet familiar with the detailed bI seesequences of the reacter accidents for.d.tch they east plaa. Cat 11 the HC cae edecate the civ11 defense plassers se to realistic vetees and Carla B. Johnston Deputy Director interrelatteaships of parameters such as the varains time before release, the Union of Concerned Scientists duraties of release, types of material released. the time of plume passage.

Cambridge, 3tassachusetta the utut of ground contaaf sattee, the dese.reducties ef fects of sheltertzg ta butidisse of verteue types, etc., the pleasers teseet ef fectively optimise DATED: August 31, 1979 altigative meseeree for the specif te plant sites withis their jortsdictions.

Until thte gap 1a br1Jged, embetaative improvecent la pwhite preteettee m

free a aucteer accident caseet be esposted. Det11 the DC bummes f aalttar with what cae and eat cannot be acccep11shed by safessed and tete!!! seat lacal energency planelag. eddittenal NRC regulaties is likaty to be of f-base and c___

J nc *cescurrence" would be seaalas tese.

MO Prior ta the tecidest at Three Mile Island Cett 2. the need for a better basis for locat emergency ptsaalms was reccgsised by AFA and MAC. Their jelat docsmaat draf t Ott'10. 4396/tPA 323/1-76-016) issued la December 1978 was a reaseeable beginalag for taprowesent. Sta11 arty. CAO's Seport ta Cergress J

to 30 March 1979 recessized the need far better preparatten la areas arewt f

J eesclear power plaat s.

It is troaic that the facident at D1 gg the out deses,u..a e, der..f

.au.de i - au t,e E,dottra.e tches goeiis.

w values for taking even velmatary protective acttee. asw threatees to metate this be61astag by farcing quick rather than sabetaatava acttene.

CW u - % e %..t.t % 3 g

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d-I Page Tao page Three

,,J, Mr. Ch11k Mr. Chilk August 29, 1979 Ausmat 29. 1979

. s-Rather them ettempt to directly answer the gseetteca la the Federal Register metace. we effer several pelats for your considerations and up asking tapeselbte er unrealistic deassds. either from their cwn A.

ne planalsa for eseqeec.tes at euclear power plaats la intensely ideerance er des to political pressere. If the NRC estataat ty approeed site-e n cifte. It should be ceneidered La a realistic manner daring a site for a meclear power plant it should be able to show by specific j

site selecties and approval. For this purpose.10CT1L100 is presentir e**epte that as acceptable emergency plan can be made far it.

j inadequate, se are current nc gaselatory Ceides os population desstry.

F.

If the NRC concurrease is required for esegency plans =1this a 50 elle 4

3.

Caves the variety of sites currently approved for euclear power radius of a reacter site. it eust have a plan for dealtag with state borders and uncooperative er varasponsive eelghteis. In the east.

plants by RC. standarised sational guidelinea for emergemey planales 1

are met 11 haly to sigallicantly improve t.he energency plans. population I'* p**er plaats have 50 alle rallt contataos deity withis e elegte etate. 88pecially if a time constratat is taposed each state can be deastty, physical barriers to evacenties. types of shelter availabt, espected ta place priority en plans for ettee withtm its borders, and

>l and other demographic factors differ to a degree ubich def tes a may If necessary. eeglect planning ta their porttons of 50 atte rtess of D

generalized planning concept. Scaething general enough to be appliable distance plants. With rivers servtag as borders for states serstco everywhere is mallkley to be specific amough to ensure res11stic pleaniss territories and even laterconnected utstity groups, power plaats at h

anyd ere, g

maar riveriae sites could haee Little taportance to the jurisdictiae directly across the river. De threat of shutdows may be taaf fectual C.

ne KRC should provide auch more specific Jatail about the klad of la productag adequate speed ta audi cases. If speed to desired, thee th situatsoes for which the plassers must prepare. Scenarios similar te the NRC mor well have to provide it throest aiequate nelstance not the releue catagories of the coassiunces model la the geactor Safety

• • • • • A***

Study would be a ensch better beats for developtag plans than is

'f.

carteetly provided ta the " plume aoses" and *1agentios sosee" of MURZG C.

During emergencies. Plant perseenet shoeld te expetted te rotata control.

I' 0394 ne NRi should esercise its judgement la deltaing these scenarios

& cadre NRC perseaset cannet be expected to became familiar with the 00 se as ta czelude those potsatial high-conseguance accidents Wich are destga one buMred dif fenst nactus and cettn1 rms to the CD of suff teiently Lou probability to pose acceptable risk Isvels without gru at ey woul e pulenble to a valt trataed snap of the s*y plaanlag beyond that level altsedy required by tf e more probable accidents, utility a **plorecs, ne HC could laprove the currect ettuatten t

f6 It, should aise cocstder the uncertainties editch were apparent dertas the by developtag regulatione and guidet!nes for emergency situation ut incident, and help provide a rattomal basis for acties during a period

" * "I #" 9 "** ^ I*

• • I III "N"*I"

""I d* "I*P I" "

• I" b

eos estettag conditteus do not require acties but future detrieration

• • "*#E*"*

A"#*

P*"****I of the situatione may occar.

developed to focus expertise en emergency situation 12strtmetatica, staulation and tratalog. n is group could alas be made available as D.

ne NgC should aake available to the total planaers the technical c

an as at us emergency, s ou t W perstt.

inforsattes regardica effectivemass of various types of altigative h

-q a

d@

seasures agata.st the various dose pettnasys* expected undet accidaat la summary, we urge that emergency planalog for nuclear reactors be conditieas. For tastance, for plume shine, inhalation and surf ace h.

h substantially 1eproved, but we caution agalmst haste. n e euphasta on timarg.

contaminattes doses. Jose reduction f acters due to sheltering ta rather than embatance la the Federal Register notice is itL advised, although las11 dings of various construction types aheald be made available.

enderstandable le the f ace of public optates.

b@4 t

3 E.

The RC should provide both techotcal and planatas anaistance to Staceroty.

the state and local civil defense personnel. If the R C adopts

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regulations requirtag adequate emergeocy plane to be implemented by e f'fd specific date, then NEC should be prepared to supply sufficient O

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consut:Ing persoemet to help a!! af fected state and local planners Steven M. Ing. ph.3.

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to prepare their plans within the time attowed, na NRC shoold be Acting Director

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preparat to provide an azample of an acceptable plan for any plaat

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power plant 51 tes 7tgram site were it feele that local officials have not planned adeguately.

k' Without this level of comattaant on the part of the 3RC.1 is sxLape h!

probable that 'the HC personnel reviewing the plans witt. La saar cases.

d ces Paul Massicat. Acting Director -

ef(

Energy Aistaistration R

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