ML20003C883

Testimony on Anti-Nuclear Group Representing York Contention III B(D),Requiring Predistribution of Thyroid Blocking Agent.Related Correspondence

ML20003C883
Person / Time
Site:	Three Mile Island
Issue date:	03/06/1981
From:	Beyea J ANTI-NUCLEAR GROUP REPRESENTING YORK
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ML20003C884	List: ML20003C883 ML20003C889
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NUDOCS 8103180630
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UNITED STATES OF AMERICA REL1Q CORPS.SPONDENCE NUCLEAR REGULATORY CCMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

__________________________________________x In the Matter of  :

METROPOLITAN EDISON COMPANY, et al.,

Docket No. 50-289 (Three Mile Island  :

Nuclear Station, Unit No. 1) [ D E

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" Stockpiling of Potassium Iodide gS for the General Public as a Condition for Restart of TMI Unit #1" DIRECT TESTIMONY OF DR. JAN BEYEA ON BEHALF OF THE ANTI NUCLEAR GROUP REPRESENTING YORK

,REGARDING A.N.G.R.Y. CONTENTION NO. III B(D) o t

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4 8103180b D

A.N.G.R.Y. Contention IIIB(D)

III(8)(0) The Commonwealth's plan.for distribution of a thyroid biccking agent to persons at risk in the event of a nuclear accident with offsite radiological consequences (da. Deat. of Health RERP, Apo. I) is deficient for the following reasons: '

1. The plan assumes an advance c:arning tine (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; p. 2) that is in excess of_that which NUREG 0654 ccncludes nay be asallable before an initial release of radioactive materials to the environment.

2. The costulated warning time is that which is deemed the minimum necessary to enable Dept. of Health efficials "tc r'cVe ahead of evacuees in their distribution efforts."

Mcweler the plan is silent with resoect tc the much mr te critical time pericd that wculd actually elacse between the initial nctification of the Cemeeneealth Of an emer-gency situation and the availability to the public of the

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medication. ANGRY suomits that given tne logistics of the distributien pectess as set forth in tP= clan such

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[ s ties paried woult! be wsil in exccas of ons hour. The l

" ass. ption" stated in Sec. IVA(1), p. 13, of the distri-but:cn clan is unsupportable as a planhing basis.

3. In tre case of York County, the movement of large numbers of people to the single designated distribution point for the *adication, the County Courthouse, would require com-plate decarture f rom predetermined evqcuation routes, particularly for residents of Fairview and norther New-berry Townshios. It would also cause massive traffic ,

congestion in the center of York City.

4 The plan would be useless in the event of a nuclear emergency for which sheltering was. the chosen protective action. It is also useless to those farmers who " consider evacuation unfeasible and elect to seek or use shelt'.ing for themselves..." (pa. Dept. of Agriculture plan, p. 17).

the stated condition to the advice to "take prescr'i'ed o

. dosage of SSKI" (Ex. 9 to App. 1, Sec. 3(c)), namely, e itsesa11 ability,wouldofcoursenotbemetundertpa plan as cresently outlined. ___.-- _ _ - - - .

For all the foregoing reasons ANCRY' submits that the only method of-distribution crs 'e of insuring the availability of a thyrcid blocking ages. 'ts cre-distribution to all potentionally affected houset .. and business, and that such pre-distri ution should be accomplished prior to the restart cf TmI-1.

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,- i Qualifications of Dr. Jan Beyea Dr. Beyea is a nuclear physicist who has specialized in the l consequences of nuclear accidents. He received his Doctorate from Columbia University. As of May 1, 1980 he became the Senior Energy Scientist for the National Audubon Society. Prior to that he was for four years a member of the research staff at the Center for En-ergy and Environmental Studies at Princeton University. .

While at Princeton University he prepared a critical analysis of models of reactor accidents.

The lessons learned from this general study of nuclear accidents were applied by Beyea over and over again to specific problems at the request of governmental and nongovernmental bodies around the -

world. These requests came to Princeton because of the difficulty local governments and organizations faced in obtaining assessments of the seriousness of nuclear safety issues by independent scientists.

Because most scientists and engineers knowledgeable about the details of nuclear issues work for organizations which are seen as having a strong. bias in favor of nuclear power, the nuclear policy group at Princeton found itself in great demand. Dr. Beyea prepared major reports on the safety of specific nuclear facilities for the Presi-dent's Council on Environmental Quality (Tf!I), for the Swedish Energy Energy Commission (Barsebeck), and the state of Lower Saxony in West Germany (Gorleben), lie examined in less detail, safety aspects of

. specific sites for the California Energy and Resources Commission, the Massachusetts Attorney General's Office, The New York City Council and, most recently, for the Governor of Pennsylvania in con-nection .with the Union of Concerned Scientists krypton venting study .

(Dr. Beyea made the dose calculations for the U.C.S. study.)

A computer program useful for reactor emergency planning was written-for the New Jersey Department of Environmental Protection.

In addition, Dr. Beyea provided advice on nuclear facility siting policy and emergency planning for the Bureau of Radiation Protection of the City of New York, the Office of Congressman Theodore Weiss, the Environmental Law Institute, the Union of Concerned Scientists, Friends of the Earch, the German Eco-Institute, the Heidelberg Univer-city Environmental Group, the Oxford-based Political Ecology Research Group as well as numerous journalists and writers.

His work has been discussed in Harper's, Science, Spectrum and few l Age magazines, in numerous books dealing with reactor issues, during his appearance on William Buckley's Firing Line and at a National Academy of Sciences debate on nuclear reactor safety.

In addition to the reports written about specific nuclear facilities, which have been widely circulated, an article of Beyea's on resolving conflict at the Indian Point reactor site and an article on emergency planning for reactor accidents have appeared in The Bulletin of the Atomic Scientists. A Princeton

. _ _ _ report with Frank von Hippel on the value of improving reactor containment systems has also been written.

A_ complete resume is attached as Appendix II.

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Su= mary of Testimony The confidence of the pubite in the institutions responsible for protecting public safety was lost at this site during the TMI-2 accident. Restoration of that confidence is essential if emergency plans now required by the NRC are to work successfully. This board can help to build confidence in the NRC (and in state agencies) by requiring as a condition of restart that potassium iodide medicine be stockpiled for the general population. Such an action will indicate that the NRC is sensitive to the special concerns of residents at this site and is insisting on backup measures which are not yet required at other sites.

TMI residents are already aware that the medicine could be useful in an accident. (The Food and Drug Administration flew in large quantities during the TMI-2 accident.) Failure by this board to require stockpiling of medicine which was actually brought to the scene of the TMI-2 accident will only serve to increase cynicism'and doubt about the sincerity of the NRC's commitment to the safety of local residents.

Potassium iodide has two important roles to play in a reactor emergency. First, the availability of .the medicine in an actual accident would have a calming effect -

on residents, thereby helping to insure that evacuation would proceed smoothly.

Second, should timely evacuation fail, or should sheltering be the chosen emergency response, ingestion of the drug would reduce thyroid doses from radioiodine by a factor of 10 to 100.

Predistribution offers the best chance of making the medicine available in those situations where it would be most useful.

-Recent conjectures that radioiodine releases in reactor accidents will be kept small by physical mechanisms are overstated--sufficiently so that potassium iodide distribution remains an important public health strategy.

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Testimony of Jan Beyea Q. What is your understanding of the Co onwealth's position on potassium iodide?

A. At the time when ANGRY Contention III 3(D) was submitted, it appeared that the

-Commonwealth was planning to stockpile the medicine, although not pre-distribute it, for the general population within the emergency planning zone. .Now, however, the Commonwealth apparently intends to provide the medicine only.for those residents who cannot easily be evacuated.

Q. You do not find this new policy to be sufficient?

A. No. I believe the Commonwealth must, to protect the public safety, require the purchase of potassium iodide in quantities sufficient to supply all residents within the 10 mile zone who might be exposed to radioiodice should evacuation plans fail during an accident or should sheltering be chosen as the appropriate mitigation strategy.

Q. Ingestion of potassium iodide under such conditions would be helpful?

A. Yes. If.taken several hours before breathing radioiodine, doses to the thyroid would be reduced 10 to 100 times, due to the blocking of radioactive iodide uptake by the already saturated thyroid. Since thyroid damage could

.,- affect more people iE an accident,(in the absence of thyroid-blocking) than any other radiation effect, this strategy could be extremely important as a mitigation measure.

The Food and Drug Administration has approved the use of potas iodide by the general population in a radiation emergency; and the Federal Emergency Managemect Agency has' urged that the medicine be' stockpiled.

Q. Is the actual protection of the thyroid ~ gland the only benefit of potassium iodide under accident conditions?

-A. -No. -The' existence of'a potassium iodide program for the genera'. population would have a calming effect'in an emergency situation. Knowledge that potassium iodide was available as a backup measure could prevent the kind

- of panic that could interfere with orderly evacuation.

Certainly, evacuation before the radioactive cloud arrives is the best

. . defense against a release of radioactivity. The fact that large numbers of people have been evacuated without panic following accidents involving toxic chemicals, flammable materials and poisonous gases suggests that evacuation is a practical way to protect at least some of the population at risk at most reactor sites. However, no one knows whether or not special fears about radiation might make this experience with evacuation invalid in the nuclear case--especially at TMI where the population is extremely sensitive to the possibility of reactor accidents. Panic over the possibility of a dreaded " nuclear meltdown" could trigger disorderly evacuation attempts even far from the reactor, preventing orderly movement of traffic. Therefore, emergency planning strategies for reactor accidents should be designed keeping in mind-the psychology of evacuation under highly stressful conditions.

The development of public confidence prior to,the o accident in the adequacy of the protective strategies available should help to wrevent panic.

Stockpiling of potassium iodide for the entire population within the 10 mile emergency planning zone will help to assure the residents of TMI-that all reasonable measures are being taken to protect their safety.

TMI residents are already aware that the medicine could be useful in an ,

accident-why else would the Food and Drug Administration have flown in large quantities during the TMI-2 accident? Failure by this board to require stockpiling of medicine which was actually brought to the scene of the TMI-2 accident e411 only serve to increase cynicism and doubt about the sincerity of the NRC's commitment to the safety of local residents. It will also i.ndermine confidence in the ability of those agencies responsible for emergency planning to cope with accidents. Members of this board and planners in the Commonwealth may believe that evacuation strategies will work well enough under _the stress of accident conditions .that potassium iodide for

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the general public will never be needed, but will the public agree?

Q .~ Presumably, confidence in public authorities is also a pre-condition for a

successful sheltering strategy?

A. Certainly. It seems unlikely that residents would obey instructions to remain near the reactor if such instructions were issued by agencies who had failed to win the public trust. And public trust will only come when the authorities responsible for emergency planning demonstrate that public safety--not economics or protection of the nuclear industry--has their highest priority.

Q. Then you believe the Commonwealth should do more in the area of emergency planning than has been suggested by the NRC?

A. Most definitely. I do not believe that the policy of providing potassium iodide solely for residents who-are difficult to evacuate is sufficient at

. this site. NRC guidelines should be considered a minimum. TMI is a special situation, with a special population. Extraordinary attention to safety must be shown by the utility, the NRC and government agencies before TMI residents can be expected to respond in an emergency with the same degree of trust as would residents at other sites.

Q. Do you think that restart of TMI No. 1 should be delayed until a general potassium iodide program is set up? .

A. Yes. I do not see how restart can be justified before every reasonable safety precaution has been taken.

Q. What is the consensus of expert opinion about the use of potassium iodide?

A .~ The distribution of potassium iodide in a radiation emergency is widely supported by radiation specialists.' However, there is considerable disagreement about the wisdom of distributing it to.the general population before an accident rather than stockpiling it.

Q. Are there any accident scenarios for which stockpiling, rather than pre-distribution,- would be suf ficient?

A. Yes. For example, in cases where the nature of the initial stages of an accident did'not appear to the authorities to justify evacuation, there would

be time to distribute the medicine at a leisurely pace as a precautionary measure. Then, should the accident take a turn for the worse and a release occur unexpectedly, the medicine would be immediately available.

However, should an accident develop quickly, only pre-distribution of the medicine would be satisfactory.

Q. Then you favor pre-distribution of potassium iodide?

A. Yes. In my opinion, pre-dis'ribution t of the medicine (fastened perhaps to all utility meters) is necessary to insure timely availability and to

. prevent distribution centers from being overrun by a panicked public.

The medicine is most effective if taken several hours before exposure (to allow time for the non-radioactive iodine to saturate the thyroid) .

Consequently, the timely availability of the medicine is crucial. And since the use of potassium iodide within the 10 mile zone should be considered as a backup strategy for use in case population movement becomes stalled, it is illogical to assume that post-accident distribution of the medicine can be accomplished rapidly.

Q. Are any other countries planning to pre-distribute the medicine?

A. Yes. Sweden has made such plans, as indicated in Nucleonics Week (8 January 1981, Page 10):

" Sweden's Radiation Protection Institute is working out plans to have potassium iodide tablets issued to all people living or working within a 20-km radius of the nation's four nuclear stations. The institute, drawing up plans at the request of the government (NW, 19 June '80, 5) estimates that about 720,000 people--almost 10% of the total population of Sweden--

will be issued the tablets.

Under the plan, residents within a 20-km radius will be sent by mail 10 tablets every other year. Others who could be affected by a nuclear accident-in which there is a radioactivity release will be able to get tablets at their jobs or at schools. Tablets will also be available without prescription at the nation's pharmacies. Full instructions on use of the tablets (one a day for 10 days in the event of an accident) will be issued along with the tablets.

1 The institute estimates that it will cost about $750,000 to l prepare and distribute tablets to residents near nuclear plants l and to have them available at places of employment and schools

-and at pharmacies. Since the tablets keep for two years, this will be a recurring cost every two years. Potassium iodide tablets contain some 1,000 times the daily adult requirement of iodide. This means that radioactive iodine is not absorbed by the thyroid gland because it is already " saturated" from the tablets. Cancer can be caused by radioactive iodine in the thyroid. It is expected that the potassium iodide tablets, which will be made by a state-owned pharmaceutical company, ACO Laekemedel, will be distributed late this year."

Q. Do you believe that residents of the TMI area are entitled to the same protection as Swedish citizens?

A. Yes, I do.

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Q. What are the principal objections to pre-distribution? .

A. First, the cost might be higher than with central stockpiles. Since_packagigg (tnan pr st bu2 costs can dominate the total cost, central stockpiling can be much cheape tiot In any case, the cost of predistributing the medicine within the 10-mile zone would be small compared to the total operating costs of the reactor.

If a 10 day supply of potassium iodide were distributed every two years to each and every one of the approximately 200,000 people living wit hin 10 miles of the plant, the cost would run $100,000 per year using the Swedish cost figures given in the Nucleonics Week story. (If the shelf life of the medicine should turn out to be longer than two years, the yearly cost would drop proportionally.) However, it is not really necessary to Predistribute a full 10 day supply. As long as one package is predistriauted to each family, coverage would be available for the entire family during the crucial early stages of an accident when population movement might be stalled. For example, one 14 tablet supply, with instructions, could be attached to every residential utility meter. A one-person family would then have a 14 day supply available, a two-person family would have a 7 day supply available, and so on. Even a seven-person' family would have a 2 day supply--giving them 2 days after starting their dosage to get to a distribution center to obtain sufficient medicine to extend the period during which their thyroids would be blocked to the full 10 days. Assuming an average family size of three,'I estimate a yearly cost of less than $50,000 using this family distribution scheme.

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In addition to worries about the cost of pre-distribution, there is some concern that pre-distribution of the medicine will unduly frighten the population. Although this argument might make sense in connection with other reactors, I think that pre-distribution of the medicine at Three Mile Island will actually lessen fear and anxiety. I find it unlikely that the inhabitants of this area, having experienced the events subsequent to IIarch 28, 1979, could be alarmed any more than they already are about the possibilities of nuclear accidents.

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There is also concern in connection with pre-distribution that people may lose the medicine if it is given to them long before an actual accident.

This is a valid point. I would prefer to see the medicine and instructions attached to utility meters, rather than having them mailed to individuals.

Nevertheless, I expect that even a mail distribution would work well at TMI, since the residents have been so sensitized to nuclear accidents that most of them would be sure to keep track of the medicine.

Q. Is attaching the medicine to utility meters a new idea?

A. No, It was publicly discussed as early as 1973 in a study performed at Oak Ridge by the Chesters. They indicated that one way of accomplishing fast i

distribution was to, "use the electric meter on each household as a pre-positioning storage point. That is, enough potassium iodate in tablet form to supply an average family could be sealed in a plastic tag and attached to the electric meter for each family. The tag could be installed and inspected regularly by the electric company with very little additional effort or cost. Repeated tampering could be discouraged by sl increasingthatmonth'sbillwhenthetaghastobereplaced."gghtly Q. Are you aware of any other concerns about pre-distribution besides the ones

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you have already mentioned?-

A. Other concerns about pre-distribution revolve around the possibility that some residents would take pre-distributed medicine . coo soon despite instructions to the contrary. People who took the medicine at the first sign of trouble at the reactor could end up exposing themselves to the risk of side effects from the medicine even though the actual difficulties at the plant were not serious.

However, the side effects from potassium iodide at the dose levels involved are generally minor and occur with such a low frequency that most likely none

.would shr- up even if 200,000 people took the drug.

Another concern about taking the drug too early is that its effectiveness might be reduced should the period of its use be extended significantly

beyond 10 days. There is some physiological basis for this concern, since

'a saturated thyroid will eventually start to give up some of the iodine which is providing the blocking. However, the decrease in practical effectiveness does not seem to be large:

First of all, publicizing such a possible reduced effectiveness would help to keep people from taking the drug before receiving instructions to do so.

Second, to get a significant reduction tu effectiveness, it would be necessary to-take potassium iodide, say, a week before the actual release.

Thus, difficulties would only arise in situations where a release was delayed for many days--a situation which would give those people nervous enough to take the medicine prematurely plenty of time to evacuate themselves and escape any exposure to radioiadine.

I agree that many TMI residents are so distrustful of official pronouncements that they might begin taking potassium iodide at the first hint of trouble despite statements by the authorities that there was no immediate cause for alarm. But such people wouldn't be the ones co stay around long enough to find out the authorities had underestimated the situation.

Q. Thus, it is you?: opinion (and that of the Swedish government) that objections to pre-distrib'. tion are .without merit.

l A. Certainly at this site.  ;

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Q. What is your opinion about recent claims by Stratton et al, EPRI and Herbert Kouts that little radioiodine would actually escape in reactor accidents?

A. First of all, it is important to note that even if such a conjecture were ptsved correct, it would not change the size of the emergency planning zone.

Iodine is only one of many radioactive isotopes contributing to the doses in those hypothetical class nine accidents studied in the Reactor Safety Study which motivated the 10 mile zone.. (See the NRC staff discussion of this point at hearings before the commission on iodine releases.8)

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However, a 1000-fold reduction in the maximum plausible radioiodine release j magnitude would probably obviate the need for thyroid-blocking--at least for adults.'" I find such a large reduction factor highly unlikely.

For instance, scientists at Battelle laboratories, after reviewing an analysis by the Electric Power Research Institute of one of the major accident sequences of concern, estimated that only a factor of six reduction would likely occur. (These Battelle comments are reproduced as Appendix I.)

It is certainly true that the solubility of cesium-iodide in water will be helpful for accident situations in which the fission produce gases are scrubbed by either the primary coolant or the containment sprays. Neither of these circumstances apply, however, for the scenarios leading to large releases in the Reactor Safety Study. Furthermore, it is by no means clear that radiciodine will in fact be released as cesium iodide under accident conditions. Apparently the presence of even a small amount of oxygen is sufficient to convert back to elemental iodine most of the cesium-iodide which is formed.

Q. It is your opinion, then, that these new conjectures about iodine chemistry.should not affect a decision to stockpile potassium iodide?

A. That is correct. Until evidence is presented which can survive peer review, it is only prudent to assume that iodine will be one of the major l, . isotopes released in any accident which will require off-site emergency measures. The worst that can happen, if such an assumption is wrong, is that money spent on potassium iodide will be wasted. On the other hand, if potassium iodine stockpiling is rejected on the basis of conjectures which later turn out to be vastly overstated, it is the public's health l and safety which may suffer.

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Q. .Do. accident sequences which lead to' releases of significant amounts of radioiodine have " nexus" to the TMI No. 2 accident?

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A. Those hypothetical radiciodine releases for which potassium iodide would be helpful are directly related to the definition of the E=ergency Planning Zone (EPZ). The EPZ concept was developed by the NRC before the TMI-2 accident. Its purpose was to deal with the residual risk from hypothetical accidents whose consequences might exceed those of design basis accidents.

Changes which have been made at TM1 Unit No. I as a result of the TMI-2 experience may have reduced the risk of a reoccurrence of the March 28, 1979 accident sequence, but these changes have certainly not eliminated (by definition) the residual risk of such a reoccurrence, nor have they eliminated the residual risk 'from all other possible accident..

Therefore, radioiodine releases are relevant to these hearings regardless of any direct connection to the modifications made at Unit No. I since the TMI-2 accident.

It should be noted that even a 0.07 percent release of the core inventory of radioiodine under typical weather conditions would cause a 10 rem adult thyroid dose to be delivered at 5 miles from the site.9 Since thyroid-blocking

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with potassium iodide is justifiable to prevent such a dose, it should be clear that potassium iodide would be a useful backup ceasure to evacuation even for very small releases.

Q. How do you recommend that the Board proceed in dealing with the potassium iodide situation?

A. I recommend that restart of Unit No. I be =ade conditional upon 1) the purchase by the Commonwealth or the utility of enough potassium iodide to supply 200,000 persons; 2) agreement by one of the parties to predistribute the medicine

. (either by mail or via utility personnel); and 3) agreement to keep all supplies fresh' through timely replacement-Q. Thank you for your testimony.

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Notes and References

1. Federal Register, " Potassium Iodide as Thyroid-Blocking Agent in a Radiation Emergency" (December 15, 1978), pp. 58798-58800; and Federal Register, (February 22, 1980), p. 11912.

2. Federal Emergency Management Agency, " Report to the President: State Radiological Emergency Planning and Preparedness in Support of Commercial Nuclear Power Plants" (Washington, D. C. : FEMA, June 1980) .

. 3. At the time of the Three Mile Island accident, potassium iodide was not available for mass distribution in the proper doses. The U. S. Food and Drug Administration therefore ordered large-scale production on an emergency basis and within a few days-had flown enough into the area in liquid form 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. In addition, packaging problems would have made mass distribution difficult: the two-and-a-half-inch droppers didn't fit the two-inch-tall bottles, and the dropper outlet

. produced too small a dosage.

-4. Luther Carter, " Nationwide Protection of Iodine-131 Urged," 206, Science, 201-206.

5. The assumption of an average family size of three reduces that portion of the total cost allocated to packages of small size. Assuming that these small packages account for 80 percent of the total cost, the $100,000 per year figure drops to $20,000 + ($80,000/3) = $47,000 per year.

6. R. 0. Chester and C. V. Chester, " Emergency Planning for Accidental Radioactivity Releases from a Licensed Nuclear Facility," (Oak Ridge National Laboratory, ORNL-4903, p. 172, 1973).

7. The risk of side effects has been calculated to lie between one in one million to one in 10 million. [ " Protection of the Thyroid Gland in the Event of Releases'of Radioiodine," National Council on Radiation Protection and '

Measurements, Washington, D. C., Report No. 55, August 1977, p. 24._/

8. Meeting on Iodine Release from Accidents and Estimates of Consequences of Nuclear Accidents, November. 18, 1980, Nuclear Regulatory Co= mission, transcript pages 132-152. In particular, Mr. Bernero, head of the probabilistic risk analysis branch, stated as follows:

"I would like to point out that there is one report that has covered this subject: NUREG 396. This is the Joint NRC Task Force Report. Even if early task forces were suppressed,

-if you go into the calcualtion and eliminate enough iodine to reduce the early fatalities,.substantially there would still be something like a 10-mile range for evacuation associated with

. these other nuclides.

The aerosol term, if one developed a rationale to substantially reduce aerosol transport in the atmosphere, then you might work on that range. But the iodine alone is not setting that range."

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(Transcript p.140.)

9.. The adult thyroid dose at 5 miles.for a worst-case 70 percent

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release is'about 10,000 rem under typical weather conditions.15*di Thus,i di"*

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!would take'a-1000-fold-reduction to bring projected adult thyroid doses down

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to'the 10 rem threshold dose which is considered the appropriate level for

- considering thyroid blocking.

Note that thyroid doses to children would.be 2 to 5 times higher.

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10. See Jan Beyea and Frank von Hippel, "Some Long-Term Consequences of Hypothetical Major Releases of Radioactivity to the Atmosphere from Three Mile Island," report to the President's Council on Environmental Quality, December 1980, Table Ei, and D. C. Aldrich and R. G. Blond,

" Examination of the Use of Potassium Iodide (KI) as an Emergency

. Protective Measure for Nuclear Reactor Accidents," NUREG/CR-1433 (Washington,.D. C.: NRC, March 1980), Table 3.

! 11. " Nuclear Reactor Accidents: The Value of Improved Containment," J. Beyea, F. von Hippel, (Princeton University, Center for Energy and Environmental

- Studies, Princeton, New Jersey, PU/ CEES No. 94, 1980) Appendix E.

12. (R. A. Lorenz et al, Fission Product Release from Highly Irradiated LWR Fuel (NUREC/CR-0722).

In 7.out of 11 experiments conducted, over 80 percent of the

-iodine' released from the fuel was collected as elemental l iodine not cesium iodide. -The experimentalists argued at

> great length that this is not inconsistent with the iodine in the fuel rod gap being in the form of cesium-iodide.

They.suggest that either trace impurities of oxygen (2 parts per million) in the steam-argon mixture used, or reactions t with the hot' quartz glass surrounding the experimental

apparatus freed the iodint from the cesium-iodide. This l .may be~true but one Louders: If it is so difficult to

keep the iodine together with the cesium under experimental l conditions; might not conditions in the reactor,, accident similarly lead to a , freeing of elemental iodine?

!- ' (The above analysis of the report has been excerpted from an October 15, 1980

. letter by Frank von Hippel to NRC Commissioner Bradford.)

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