ML20093N525
| ML20093N525 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/30/1984 |
| From: | Mcmurray C, Radford E, Saegert S CITY COLLEGE OF NEW YORK, NEW YORK, NY, PITTSBURGH, UNIV. OF, PITTSBURGH, PA, SUFFOLK COUNTY, NY |
| To: | |
| References | |
| OL-3, NUDOCS 8408020021 | |
| Download: ML20093N525 (16) | |
Text
4 94; n,y RELATED C;;;,iSl'GNDENg UNITED STATES OF AMERICA 37.g _ _'d_
ug V, NUCLEAR REGULATORY COMM:SSION
- n Before the Atomic Safety and LicensiEd Board $1,54 In the Matter of-
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station, )
- Unit 1)
)
)
DIRECT TESTIMONY OF EDWARD P.
RADFORD AND SUSAN C.
SAEGERT ON BEHALF OF SUFFOLK COUNTY CONCERNING CONTENTION 16.E
.Q.
Please state your name, occupation and qualifications.
A.-
LMy name~is Dr. Edward P.
Rad fo rd, and I am an Adjunct Pro-fessor of Epidemiology at University of Pittsburgh.
I received my M.D. degree from the Harvard Medical School in 1946.
One of my specialties is the subject of the health effects of ionizing
-radiation, which I have taught at the Harvard University School of Public Health, the' University of Cincinnati School of Medi-cine, Johns Hopkins University School of Hygiene and Public Health, and the University of Pittsburgh.
I am presently visiting scientist of the Radiation Effects Research Founc Lon
.in Hiroshima where I am conducting research on new data that have.been compiled regarding the health effects of the atomic explosions in Japan in 1945.
My professional 6.hD Tsoo FC' o 000 22 d
o
?" ^
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Facth in :ny cur riculum qustifications and background ace sat vitae which was Attachnent 3 to my testimony concecoing Conten-tion 61.
My name is Susan C.
'ia a J e t t.
I am an Associate Professor of Psychology and Unvitannental Paychol.ogy at the City Univer-sityf of New York Graduate School.
My professional qualifica-tions1 ace ~ descr ibed in my cut riculum vitae, which was sub:.t it:31 and admitted into evidence as an attach.nent to ny i.eitinoly an
' Contention 65.
See Tr. 2259.
Q.
What is the pocpose of this testimony?
A.
[Radford, Saeg er t]
The purpose of. this testinony is to y
_ address Contention 16.E which reads as follows:
Co n te n t io n,1,6,.
LILCO has drafted a public education brochure entitle.1 "Energency Pto-celuces:
3hoceham. Nuclear Power Station."
The content of-LILCO's public _ information brochuce is.ni.si n.iing and incomplete and
' thus this aspect' o f the public 'information program fails to comply.with 10 CFR Section 50.47(b)(7), 10 ~ CFR Par t; 50, Append ix 3,Section IV.D.2, and NUREG 0654, Sections II.G.1 and'2.
In particular:
r E.
The LILCO brochute's discussion of r4-diation ef fects -is limited to' natural soucces and very_ low levels of radiation.
It does not adequately address tne nagni-tude of ' doses that the public inight cecelee
- ducing a severe accident, such as one -
p; 2:
'l-3t ro:ptiting EPZ evacuation, nor the health-threatening consequences related to
.such releases.
Such inadecptate.lisclosure of essential facts renders the bro.:hore in-credible.
2
~ DoLyou agree with Contention 16.E?.
4.-
(Raiford, Saegert]
Yes we do.
LILCO's brochure is void
.of any neaning ful discussion of the magnitude, and eEEects of exposure to, the levels of radiation that coni.1 be released into the': environment during a serious accident at Shoreha n.
Rather, the brochure is replete with infor. nation about ra3 La-tionEexposure-levels experienced in our everyday livea.
Al-
- thoug'h such ' in formation-is no t in itse1E inaccurate, it is mis-Lleading in the context of a discussion of what could happen in
'the ~ event of an accident at the Shoreham plant because the dis-
~
cussion' of natural and very low levels of radiation does not
-contribute to an understanding of the need to protect one's
.self and Ea:ntly. Ero.n the-higher exposures which could result g
Eton an accident.
Furthermore, the brochute contains 3.nis-1?iding illustration which misrepresents the dose savings like.
ly to-be achieved by sheltering, m
The purpose of a-brocnure such as LILCO's is to inforn tne public of the nature of the risk should an accident occur irequiring : protective actions.
Only if the pubiic is informed -
m of the true nature of the risk is it reasonable to expect taat paaple will atte ngt to take appropriate protective actions.
Inaccurate and incomplete information such as th at found in the LILCO brochure renders the brochure ineffective and inadequate
- as a method of infor ning the public about why planning for a radiological emergency is necessary.
Q.
-What does LILCO's brochure tell the readers about r ad ia-tion?
A.
(Radford, Saeger t]
LILCO's brochure at pages 14-15 de-i.
scribes a few interesting facts about radiation; however, in the contek t o f - a d iscussion o f emergency planning, those facta are largely irrelevant and present a distortal and misiesding picture to-the public.
Psge 14 is entirely devoted to naturally-occurring levels of radiation.
It notes, for exaia-ple, that radiation is everywhere, that it is easily detectad,
- andLthat someone living in New York would probably receive a total of about 200 millitems a year from natural sources ( e. g._,
cosmic. radiation, food and air) ani nanmade sources (e.g., med-
~ical-x-rays and consumer goods).
On page 15, the brochure goes on to explain ~that a person living near a-nuclear power plant
'which-is operating normally would receive "at most only 1 to 2 millitem.a year."'
' E
IN It is only after more than a page of this sort of informa-tion that-the LILCO brochure finally asks the relevant ques-tion, "What about radiation released as a result of a reactor accident?"
The brochure's answer, however, is evasive and l
unresponsive and could lead the reader to question the rele-vance of the brochure to the event he is supposed to be receiving information about.
The response to the question is that the 75 nuclear power plants operating around the country have never experienced an accident that exposed the public to a
-level of radiation above natural levels.
A brief reference to the accident at Three Mile Island also tells the reader that the average dose to the public within five miles of that plant was about 1 millirem.
The effects and possible exposures in
'the event of a serious accident at Shoreham, however, are com-plately ignored.
Q.
Why is.the information in the LILCO brochure inadequate?
A.
[Radford, Saeger t]
The discussion of radiation and possi-ble radiation exposures is inadequate because it does not tell the reader what doses would be possible during a radiological-emergency at Shoreham and how taking appropriate protective ac-tions could help to re' duce those doses.
Apparently LILCO con-siders the level-of radiation one receives from a luminous -. -
. watch, a smoke detector or from living in Denver to be relevant to a discussion of planning for an emergency at Shoreham (see page 14).
Even assuming for the sake of argument that such matters are relevant, they are certainly no more relevant than the potential consequences of the very incident the brochure is supposed to address - a radiological emergency at Shoreham
' requiring protective actions on the part of the public.
Al-th'ough information on the potential consequences of an accident exists and'could be included in the brochure, LILCO nas failed to include any such information.
Q.
What additional information should be included in the bro-chure?
A.
[Radford, Saegert]
The information about radiation relating to a Shoreham accident which should be included in tne brochure falls into two general categories.
The first category is the range of potential radiological exposures which could
-occur as a result of a severe accident at Shoreham.
The second category is the potential health consequences of such expo-sures.
. [ Rad fo rd]
Information exists with respect to both sub-jects.
See, for example, the Testimony of Fred C.
Finlayson, Gregory C. Minor and Edward P. Radford on Behalf of Suffolk.. -. -.
V County Regarding Contention 61, which sets forth the potential doses.which could result from a severe Shoreham accident involving the release of radioactive material, the potential dose reductions that could be achieved through the use of vari-ous. types of shelter in the EPZ, and the potential doses to the public who are in automobiles with no access to shelter.
In addition, Science Applications Incorporated and Pickard, Lowe &
Garrick have performed a probablistic risk assessment and con-sequence analyses, respectively, concerning potential accidents at Shoreham, on behalf of LILCO.
Thus, information concerning the range of potential exposures and the potential doses and health effects from such doses is available but has not been included, or even referenced in the LILCO brochure.
(Radford, Saegert]- The LILCO brochure includes, at page 16, a brief discussion of federal guidelines on acceptable ex-
_posure limits; however, it does not say anything about the re-lationship of such exposures to those that could occur during a Shoreham accident, or the health consequences of exposure to the levels of radiation that could occur during an accident at Shoreham, which could be far above the limits set forth on page 16. -
5 0 What shouldLthe brochure say about health effects?
A.
[Radford, Saegert]
In our opinion, the public should be given a brief and accurate description of the health effects --
both early and delayed -- that could result from the exposures that might be received from the wide range of possible acci-dents at Shoreham.
. [ Rad ford]
The public should be told that the health effects of: radiation can be divided into two basic categories -
"early" effects (somet'imes called " acute" effects) and delayed effects'; that early effects which may include fatalities or in-
. juries, generally occur from within a.few days to 60 to 90 days after exposure, and that. delayed effects (sometimes called "la-
' tent" effects) may occur at any time throughout the normal lifetime of an individual af ter exposure.
Latent periods of 10
. years or more (during which no effects would be medically observed in an exposed individual) are common to most delayed effects.
With respect.to early effects, the brochure should tell the reader.that the threshold level at which early death occurs is_about 200 rem, irrespective of treatment methods for exposed individuals and that given minimal standards of medical treat-ment after exposure, there is a 50 percent risk of death within E
'k 60 days from an exposure of 300 rem.
The public should also be informed of the symptoms of radiation illness, which is charac-terized by vomiting and lethargy.
The individual risks of early illness range from a 30 percent chance at 100 rem, to 80 percent chance at 300 rem to almost 100 percent at 400 rem; the chances of incurring early illnesses that might require treat-ment become negligible. at doses of less than 50 rem.
The pub-lic should also be told that detectable changes in blood cells
.is commonly associated with doses of 25 to 30 rem.
With respect to delayed effects, the brochure should in-
-form the reader that delayed effects include cancers, teratogenic effects on the developing fetus, and genetic.
effects, and that cancer is the most common delayed effect.
In order to put the risk of cancer from radiation exposure into perspective, the brochure should state that while the average person has about a 28 percent chance of contracting cancer (other than akin cancer) and about a 17 percent chance of dying from it, a dose of 30 rem will increase a person's chance of contracting cancer to about 34 percent.
Finally, the public should be told that a 200 rem dose ( aside f rom the early effects) will more than double the chance of contracting cancer from 28 percent to 60 percent, and that roughly half of all contracted cancers, except skin cancer, are fatal.
~Q.
Why_should the type of information you have described con-cerning potential levels of exposure and the resulting health effects of such exposures be included in LILCO's brochure?
A.
[Radford, Saegert]
The public is generally not well informed about the health consequences of radiation.
Radiation is simply not a commonly-confronted disaster agent.
People know that if a person is swept into a flood and kept underwater for longer than he can hold his breath, he will probably die.
Likewise, the public generally knows that if a person is caught unprotected-in a tornado or hurricane, he could be thrown vio-lently by the: wind or struck by flying objects.
In contrast, people. do not generally know very much about the consequences of radiation exposure.
We believe all_ parties agree that a person's perception of the risk of exposure will certainly influence his actions dur-ling an emergency.
(See LILCO and Suffolk County Testimony on
-Contention 23).
Yet, the LILCO brochure does not provide ade-quate information to help the reader form an accurate percep-y tion of..the risk that could exist during a radiological emer-gency.
If a person believes that he will die from a 5 rem dose, he'may.try to evacuate no matter what protective action LILCO' recommends.
Likewise,-one who thinks that exposure to -m
- n t
c
~ 200 rem does not sound so bad, and that evacuation is not worth the security risk of abandoning his home, might reconsider if he knew that exposure to such a dose would almost certainly make him ill and would double his chances of cancer induction
- as well.
Furthermore, without some basic factual information about radiation doses and their effect,.the data in LILCO's
-proposed EBS messages concerning projected doses would be mean-ingless.
In short, the additional information we have proposed is crucial to the public's understanding of the risk, which in turn will help them understand, and make informed judgments about their response to, the protective action recommendations to be made by LILCO.
Q..
Do you have any other concerns with respect to the LILCO brochure's discussion of the magnitude of potential doses dur-
.ing an emergency or the health consequences of such exposures?
A.
[Radford, Saegert]
Yes.
On page 7 of the brochure, LILCO has included a very misleading drawing which depicts a family sheltering inside its home.
Radiation, represented by arrows, is shown to hit the house and bounce off like rubber balls.
No
. rad at on is shown as entering the house.
Thus, the drawing i
i strongly implies that, no matter what the radiation level is outside the home, one will suf fer no exposure (and consequently experience no adverse health effects) if one stays inside.
.This is grossly inadequate and misrepresents the value of snel-1 tering, which lies in dose reduction, not dose elimination.
[Radford]
By LILCO's own admission, the average shielding factor from a cloud dose for a residential home in the FPZ is
.7.-
(OPIP 3.6.1 at 36).- That means that even if one shelters at home, one will receive on an average about 70 percent of the
[ dose one would receive if outside the home.
Thus, to be accurate, the drawing should show at least some of the arrows representing radiation penetrating the house.
The way the drawing stands now, however -- with radiation depicted as bouncing off one's house -- is very misleading.
[Radford, Saegert]
Indeed, a person looking at the pic-ture would say, "Why evacuate?
My house offers complete pro-tection."
In cases where evacuation was required, this LILCO-induced nisconception could threaten the health of the public.
Certainly it makes LILCO's brochure inaccurate and thereby reduces the chance that the public will take appropri-ate protective actions.
Likewise, a person with some knowledge about the' efficacy of sheltering would recognize that the draw-ing is misleading and, as a consequence, might dismiss the en-tire brochure as inaccurate.
Again, this would reduce the '
e:;
..= -
-.i.
chance-that'the public will take appropriate protective
- actions.
..v
- [~
. Q.-
. Does this: conclude your testimony?
s A.;
[Radford, Saegert]
Yes.
i s
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4 6,
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v UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY CCMMISSION Before the' Atomic Safety and Licensing Board
)
In-the Matter.of-
)
)
LONG' ISLAND LIGHTING COMPANY
)
Docket'No. 50-322-OL-3
)
(Emergency Planning)
~(Shoreham Nuclear Power Station,
)
Unitil)'
)
)
CERTIFICATE OF SERVICE
'I;hereby certify that. copies of Direct Testimony of Edward P. Radford-and Susan C. Saegert on Behalf of Suffolk County Concerning Contention 16.E have been served to the following this'30th day of July, 1984 by U.S. mail, first class, except as otherwise noted.
- James A.
Laurenson, Chairman James B.
Dougherty, Esq.
- Atomic Safety and Licensing Board 3045 Porter Street, N.W.
U.S. Nuclear Regulatory Commissien Washington, D.C.
20008 Washington, D.C.
20555
- - Dr.~ Jerry R.'Kline Marc W.
' Administrative' Judge Energy Research Group, Inc.
<: Atomic Safety and Licensing Board 400-1 Totten Pond Road U.S.. Nuclear' Regulatory Commission Waltham, Massachusetts 02154 Washington, D.C.
20555-
- W.' Taylor Reveley, III, Esq.
- Mr. Frederick J. Shon Hunton & Williams Administrative Judge P.O. Box 1535 1
' Atomic Safety and Licensing Board 707 East Main Street UI.S.. Nuclear Regulatory Commission Richmond, Virginia 23212 Washington, D.C.
20555 Mr. Jay Dunkleberger New York State Energy Office
-Edward M.
Barrett, Esq.
Agency Building 2-2
General Counsel Empire State Plaza Long' Island Lighting Company Albany, New York 12223 250 Old Country Road
.Mineola, New; York 11501 y..
??
~~
~...
Mr. Brian McCaffrey Stephen B.
Latham, Esq.
-Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station P.O.
Box 398 P.O.
Box 618 33 West Second Street i
North Country Road Riverhead, New York 11901 L
Wading River, New York 11792
'Joel Blau, Esq.
MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter F. Cohalan Suffolk County Executive Martin Bradley Ashare, Esq.
H.
Lee Dennison Building
'Suffolk County Attorney Veterans Memorial Highway
.H.
Lee Dennison Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Stuart Diamond Business / Financial Atomic Safety and Licensing New York Times Board Panel 229 W.
43rd Street U.S.
Nuclear Regulatory Comraission New York, New York 10036 Washington, D.C.
20555 Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Appeal Board U.S.
Nuclear Regulatory Commission U.S.
Nuclear Regulatory 1717 H Street, N.W.
Commission Washington, D.C.
20555 Washington, D.C.
20555
- Bernard M.
Bordenick, Esq.
Jonathan D.
Feinberg, Esq.
Edwin J. Reis, Esq.
Staff Counsel U.S.
Nuclear Regulatory Commission New York State Public Washington, D.C.
20555 Service Commission 3 Rockefeller Plaza "O
Stewart M. Glass, Esq.
Albany, New York 12223 Regional Counsel Federal Emergency Management Nora Bredes Agency Executive Director 26 Federal Plaza, Room 1349 Shoreham Opponents Coalition New York, New York 10278 195 East Main Street Smithtown, New York 11787
- Elaanor L.
Frucci, Esq.
Spence Perry, Esq.
Atomic Safety and Licensing Associate General Counsel Board Panel Federal Emergency Management U.S.
Nuclear Regulatory Commission Agency Washington, D.C.
20555 Washington, D.C.
20472 a
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Y' e:f,-c ;._
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- Fabian Palomino,. Esq'
-Special Counselito'the Governor
-Executive Chamber State' Capitol
- Room 229.
, Albany, New York 12224
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c Chr13topher M/ McMurray j
KIRKPATRICK, LOCKHART, HILL,
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CHRISTOPHER & PHILLIPS
/
1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036
. Dated:
July 30, 1984~
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'By_ Hand ByJFederal Express
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