ML20058E049
| ML20058E049 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/23/1982 |
| From: | Solon L NEW YORK, NY |
| To: | |
| Shared Package | |
| ML20058D615 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8207270474 | |
| Download: ML20058E049 (12) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges Louis J.
Carter, Chair Frederick J.
Shon Dr. Oscar H.
Paris
g In the Matter of:
Docket Nos.
CONSOLIDATED EDISON COMPANY OF NEW YORK 50-247 SP Inc.
(Indian Point, Unit No. 2),
50-286 SP i
POWER AUTHORITY OF THE STATE OF NEW YORK July 23, 1982 (Indian Point, Unit No. 3)
x Testimony Submitted on Behalf of "New York City Council" Intervenors By DR. IlXNARD SOIIN This Document Has Been Filed By:
NATIONAL EMERGENCY CIVIL LIBERTIES COMMITTEE 175 Fifth Avenue Suite 712 New York, New York 10010
-( 212 ) 673-2040 CRAIG K APLAN,
SPECIAL COUNSEL 8207270474 820723 PDR ADOCK 05000247 T
s Feirm -f. A g @ 65. WORTH ST.,NEW Bureau for Radiation Control DEPARTMENT OF HEALTH Telephon.: (212) 334-7761 Statement to Atcmic Safety and Licensing Board of the U.S.
Nuclear Pegulatory Cmmission Re: Continued Operation of Indian roint Nuclear Paactor Electric Power Generating Stations in Duchanan, Kestchester County, Nc41 York Dr. Leonard R. Solon Director, Eureau for Radiation Control N.Y.C. Department of Health 1
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i Biographical Summary for:
Dr. Leonard R. Solon, Director Bureau for Radiation Control
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New York. City Department of, Health e
' I# " ', I P' '65 Worth Street
,. JJ3.!1 New York, New York 10013
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Dr..Solon' received his~ bachelor's degree from Hamilton College in 1947, his Master "of' Science degree in ~ physics from-Rutgers Univer' ity in s
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'.1949,~and his Ph.D. :in' radiological health from New York University in 1960 He was elected to Phi Beta Kappa at Hamilton College.
His doctoral i
dissertation;at New York University was on the dosimetry of natural environ-(
msntal ionizing radiation.
In addition to his present position as Director of the New York City Health Department Bureau for Radiation Control, he currently holds an appointment as adjunct associate professor in the Department of Environ-(
mantal Medicine of the New York University Medical Center where he organized l
and taught graduate courses in radiological health, radiation hygiene measure-l mants,'and the health effects of non-ionizing radiation.
He is a co-patentee of the laser photocauterizer employed in the treat-
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He is also a co-inventor 1.
covered by a United Sta.tes patent of a method of powering laser devices using nuclear energy sources.
Among his prior positions, Dr. Solon was Assistant Chief and then Chief of the Radiation Branch of the United States Atomic Energy Commission Health and Safety Laboratory (now the Department of Energy Environmental Measurements -
Laboratory).
He was also a member of the Technical Consultants Panel of the Atomic Energy Commission, Division of Military Application.
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' -., His professional organizations include membership in the Health, Physics Society, the-American, Nuclear Society, the American Association for'.the AQvance'-
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ment of Science)*the' American Physic'al Society,.the New York Academy of Sciences,.
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t and'the Conference of Radiation Control. Program. Directors....
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.He is' certified as'a health physicist with certification by the American.
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Board of Health Physics and.is listed'in American Men and Women of Science.'
,'Dr. Solon'was born in White Plains, New York.
He attended New York City public. schools including the Bronx High School of Science from which he graduated prior to. eritering college.
During World War Two, Dr. Solon served in a heavy weapons company with I
the 87th Infantry Division in Europe where he.was' awarded the Combat' Infantryman tadge'and received battle, stars for the Ardennes, Central Europe,'and the Rhineland.
Dr. Solon.was married.to Charlotte Rothman of New York in 1946 at the sonclusion of his military service. They have three children,. Miriam, an editor,' lawyer end graduate of Cardozo School of Law of Yeshiva University in 'New York C'ity;
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fatthew,anartistandteacher,who.receivedhisMasterofFineArtsdegreefrom i
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%he University of Arisona, and Emily spresently;an. art' student,at. Parsons School of pesign.
l Dr. Solon shares his scientific interests with his new grandson, Idan Samuel Solon..
forninJanuary,1981.
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Introduction I am Dr. Ieonard R. Solon, Director of the Bureau for Padiation Control of the City of New York Depart: rent of Health. Q/ ccmnents are at the invitntion of twenty-three members of the New York City Council.
Before furnishing my observations to the Nuclear Regulatory Camission's Atomic Safety and Licensing Eoard I would want to rake a few prelim.inary rerrarks and express a qualifying caveat.
Though I am here with the knowledge and authorization of Dr. David J.
Sencer,:
Cmmissioner of Health of the City of New York, the opinions I express are my personal scientific perceptions and evaluations.
They do not represent the point of view of the New York City Department of Health nor that the New York City Board of Health which, to my knowledge has not taken an official position in the matter of the Indian Point reactors.
Ibwever the involvement, concern, and interest of the Department and Eoard has been long standing.
As early as August 12, 1976 the Department, at the direction of the Conmissioner of IIealth and the Board of IIcalth scheduled and arranged for a detailed scientific public hearing before the Peard on the health implica-tions of the operation of the Indian Point nuclear reactors in Buchanan, i
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Westchester County, New York.
One brief coninent on my own personal orientation in this ratter.
I do not propose to address in nrf remarks any overall evaluation of' the general l
exercise of the nuclear poaer option with respect to confronting the City, State, or Nation's energy needs. Ucsever menbers of the Atomic Safety and Licensing Board and the concerned public are entitled to kncu as our youthful conterporaries so eloquently phrase it "where I am c: ming frcm."
In my personal judgment a defensible case has been rade for the utilization of nuclear reactors for electric power generation to meet, alcng -
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with otha energy sources, present requuements for the United States and New York State. From the occupational and public health and safety viewpoint, a supportable position can be advanced generally favorable in the nuclear option as contrasted with fossil fuel - oil and coal fired Exuer plants.
For reasons whidt I have published elsewhere, I am hopeful that the nuclear fission optior with whidi I think we are capelled to live for perhaps thirty years, will be universally replaced with superior advanced technoloaies such as laser-induced fusion or solar power. thever that is a subject for another day and another forum.
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On Indian Point ibday's question is not the generic merits of the nuclear pwer option.
The very serious matter upon which we are focussing attention are the specific public health questions 'and risk-benefit constraints associated with continued operation of Consolidated Edison's Indian Point-2 and P wer Authority of the State of New York's Indian Point-3.
After careful study and consideration of the total ccq31ex of decisive parameters, it is my. scientific judgment that the continued operation of the Indian Point nuclear reactors can no longer be justified in terms of the potential danger to public health. The risk-benefit equation is weighted significantly unfavorably in tents of hazards and I urge that the Nuclear Pegulatory Cmmission operating licenses for the Indian Point nuclear reactors be rescinded as soon as possible.
The principal practical paraneter that must be taken into account and for which appropriate accminodation is required is the 20% of required electric power nw supplied to the City of New York metro 5clitan area by the Indian Point generating stations. Powever in the public health balance this loss of generating power can no longer be regarded as preemptive. I will suntrarize my personal scientific perceptions for urging an early shutdwn of the Indian Point reactors. In the aggregate, the collective reasons are so fundamental that one cannot anticipate adequate I
corrective measures to warrant reinstituting an operational license after its reccmnended carrellation.
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Location of Site and Population Density.
The Indian Point reactors are located on the east bank of the Hudson River 24 miles frm the New York City northern boundary in the borough of the Bronx.
Within a 50-mile radius of the asuplex there is a densely-repulated area.ncompassing 17 million people in the States of New York, New Jersey, Connecticut and Pennsylvania. Very nearly all of the 8 million residents of New York City including all of Manhattan, Brooklyn, Bronx, Queens, and most of Staten Island fall within this 50-mile radius.
There is absolutely no doubt that the present site of these reactors, the progenitor of which, the now permanently shu.t-down Indian Point-1, which began commercial operation in 1962, would be regarded as utterly unsuitable by today's siting standards for nuclear pcwer generating plants.
It can be validly argued perhaps that in 1973, when Indian Point-2, or much less validly in 1976 when Indian Point-3 had its initial startup, there was l
insufficient siting information available to reach decisions with regard to the adequacy of the Indian Point location.
Seismic Potential of Ramaco Fault Though it is well knoan to the Atmic Safety and Licensing Board, l
since it was subject addressed by them in their decision of October 12, 1977, a
it is not generally known even in the scientific cxrtnunity, that the first Indian Point nuclear plant did not meet the NRC design stardard for seismic i
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resistance to earthquakes of 0.15g ground acceleration.
The geological Ramapo fault couplex is under the Hudson River 3000 feet i
west of the Indian Point site and though adjudged not a capable fault under i '
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Appendix A 10 GR Part 100, Seismic and Geologic Siting Criteria for Nuclear Power Plants, it has been inccmpletely evaluated with respect to earthquake hazard according to the detailed studies of Aggarwalg and Sykes at the Lamont-Doherty Observatory of Columbia University. thether the design of Indian Point-2 or Indian Point-3 to sustain a Fodified Mercalli Intensity VII earthquake shock (which I am advised is roughly equivalent to a Richter Magnitude 5.5) is sufficient for the Buchanan location is still an unresolved question.
'Ihyroid Blocking Agents Despite the incredible reconmendation in the New York State Radiological Bnergency Preparedness Plan (P.III-55) against the use of potassium iodide as a protective preventive therapy for a ra%ctive iodine release in a nuclear accident, rest of us who have considered the problem in serious scientific depth share the view that potassium iodide should be stockpiled and immediately accessible. Unfortunately the New York State rea:mnendation, reinforced by the scientifically indefensible position of the New ork Academy of Medicine in a similar comnunication last year of its Ccomittee on Public Health on this matter, means that the 17 million people within 50 miles of Indian Point have hanging over their heads indefinitely the l
Damocletian sword of thyroid malignancy as long as Indian Point-2 and Indian Point-3 remain operating. As a physicist, I am not reassured by the observa-tion of some of my medical colleagues that thyroid cancer is not the worst of cancers.
If it develops it can probably be detected and diagnosed before metastasis and the matter can be readily handled by surgical excision of the thyroid. However a medical public health resident of the Health Departrent and myself published in the October 1981 Bulletin of the Atomic Scientists a public health calculation which puts the matter in.
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perspective.
If the 8 million residents of New York City were exposed to an average of 10 rem per person during a nuclear accident about 7000 cases of thyroid cancer and 20,000 cases' of abnonnal non-malignant nodules could occur in the first 20 years. If the average person lived 40 years after the accident, there would be 14,000 cases of thyroid cancer and 26,000 persons with benign nodules.
In medical practice an extensive series of tests would be required to distinguish between a cancerous and non-cancerous lesion. The former of acurse, would have to be renoved by a surgical thyroidectany.
Using 1979 dollars the projected care for New York City residents alone afte.r a serious nuclear release including radioactive iodine-131 and iodine-133 would be about $9.6 billion for outpatient prevention and follow-up, $128 million for removal of 14,000 cancerous nodules and $163 million dillars for removal of 26,000 benign nodules.
Members of the Atanic Safety and Licensing Board certainly know and the infonned citizens of New York State ar.d New York City should be made aware that if auchanan, New York was in southeast Tennessee and Indian Foint was the WA Sequoyah nuclear plant, the residents of Buchanan would have l
l available in their hanes protective blocking doses of potassiun iodide.
hhy the Tennessee Departuent of Public Health has taken this manifestly warranted important step which is being denied our neightors in the Tam of Cortlandt deserves scientific and regulatory agency attention.
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General Public Health Problems decisively Hcwever, the overall problen would not be
' ameliorated even if potassiun iodide were made ac ssible to people in the 10-mile radioactive plume exposure pathway or the 50-mile ingestion exposure pathway.
The comon sense scientific fact is that having more than 8 percent of the United States population at public health risk fran the unacceptable location of the Indian Point nuclear generating complex cannot be justified in terns of current knowledge.
It is proper for the Atanic Safety and Licensing Board to be involved and concerned in matters such as the mathenatical relationship between radiation induced cancer and radiation dose fran a nuclear accident.
Whether the appropriate equation is linear, quadratic, linear quadratic or sareth.tng else or whether or not ehere is a threshhold for malignancy are matters of profound scientific concern and interest and would influence many long-tern decisions of regulatory agencies concerned with all aspects of radiological health and safety. However, a parameter upon which I think we can all agree is that though one radioactive induced cancer in our j
population is undesirable and if possible slould be avoided -10,000 canmrs are a disaster.
The population at risk in terns of Indian Point is simply too large to allow continued operation of these nuclear plants.
In the acordinate system of 17 million men, kmen, and children within l
50 miles, it is evident in terms of the latitude of many uncerta.inties, I
that the effectiveness of sheltering, evacuating, radioactive decontamina-tion, and medical treat =unt following a rajor category nuclear accident are probably g6ing to be inadequate.
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It is in the primary health and s:..;ty interest of our people -- and paradoxical as it may seem - even in atinued sensible exercise of the nuclear option itself in confronting hnerican energy needs - that the operating licenses of Indian Point-2 and Indian Point-3 be pennanently rescinded.
Thank you for your kind attention.
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