ML20135B217

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Submits Concerns Re Current Status of Potassium Iodide
ML20135B217
Person / Time
Issue date: 09/24/1990
From: Crane P
NRC
To: Thompson H
NRC
Shared Package
ML20135B134 List:
References
NUDOCS 9702280134
Download: ML20135B217 (5)
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Text

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September 24, 1990 ]

i Abyk MEMORANDUM FOR: pagH L. iompson, Jr.

l FROM: Pe f r Crane 1

SUBJECT:

POTASSIUM IODIDE DPO i

My concerns about the current status of the potassium iodide  !

DPO include the following: l

1. Instructing the staff to revise NUREG-CR-1433 will l accomplish nothing if that instruction is not accompanied by i guidance as to what is wrong with the existing cost-benefit analysis. In the absence of such guidance, the staff is merely correcting some of the inaccuracies in the numbers used in the NUREG, as recommended by the DPO panel. (One of the members of the DPO panel has been assigned the task of revising the NUREG.) The staff has yet to come to grips with a crucial point of the DPO: that the problem with the .

NUREG was not just one of inaccurate numbers, but also, more j fundamentally, of an erroneous anoroach to applying '

cost-benefit techniques to an issue of public health policy (see 2. below).

The EDO's office knows the approach used by the staff and the DPO panel; it knows the criticisms of that approach made in the DPO and subsequent memos. A timely resolution of the difference between the two can only serve the 1 Commission's interests. If the DPO's criticisms are correct, then the staff member should be advised of that before a year's work on the NUREG revision is misdirected.

If, on the other hand, the EDO believes that the DPO's criticisms of the staff's approach are meritless, then it should so inform the Commission and me.

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2. Among the deficiencies of the staff's approach, the following stand out:
a. The cost-benefit analysis of NUREG-CR-1433 mechanistically balanced the cost of KI pills against the ,

cost of treating the cancers and nodules that can be expected to develop if KI is not used. The DPO panel followed the same approach. In reasoning that it does not make sense to spend more on preventing a given number of cases of disease than it would cost to treat those cases if they occurred, these analyses implicitly took the position that it is just as desirable to develop a disease and have it treated as it is not to have the disease in the first place. That approach fails the test of common sense:

obviously, disease prevented is preferable to disease cured.

It follows that society (and individuals) may want to spend s more to prevent a particular illness than it would cost in 9702280134 970226 ,

PDR ORG NIRCTN PDR

dollars to treat that illness if it occurred. How much more 4 - depends.on the nature of the illness.

b. For cost-benefit analysis to have any usefulness, .!

when applied to a disease prevention ~ measure, there must be a serious attempt to come to grips with the totality of the

< costs associated with having the illness. That does not /

simply mean doctor. bills. It also. includes, in straight I

[

economic costs, loss of productivity. The diversion of

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medical resources from other concerns should also be taken I into account.. There are also non-economic' consequences of the illness in question that may be far greater than the

. dollar costs. (Moreover, some aspects of an illness, though extremely unpleasant, do not lend themselves to treatment, 3- and thus do not show up'on medical bills.)

The real costs of an illness thus cannot be assessed I without asking some basic questions of competent medical

authorities
How disagreeable is the illness? What are its j consequences in terms of the quality of life? How complete and successful is treatment? How burdensome is treatment? -l

, NUREG-CR-1433 avoided all such inquiry, and so did the

{ report of the DPO panel, notwithstanding that the issue was

raised prominently in the DPO.

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I realize that the objection might be made to such a j line of inquiry that the NRC is not competent to make

! qualitative judgments about the burdens. created by an i illness. There are two answers for that: first, that with

a few phone calls, the NRC could obtain expert advice about
the nature and consequences of various illnesses. Second.

if the NRC, even with advice, cannot make qualitative i judgments about diseases, then it cannot purport to make

! cost-benefit judgments about measures to prevent those diseases.

c. A cost-benefit analysis that assumes that a major accident in which KI would be useful will occur only once every thousand years should not only explain the basis for 2 that assumption, it should also make clear the uncertainties
surrounding that estimate.
3. It was on April 16 that the EDO directed the staff to prepare a Federal Register notice informing the public that the-NRC would revise NUREG-CR-1433 and that the NRC would participate in the new review of the potassium iodide

' issue that an interagency panel of the Federal Government would be conducting. Five months later, and two months j after the interagency panel held its meeting on the KI issue, the Federal Register notice has yet to come out. (I 2 am aware that the text of a Federal Register notice has recently been approved -- I have not seen it and do not know

a -

9 its contents -- but.the fact that it has taken so long says

, something about the priority this matter has been accorded.)

i I note from the attached trip report that "There was no ,

opinion expressed by the [ interagency) group as to whether the NRC should publish a Federal Register notice at this

. ' time." I would not have thought, after the EDO's memo of

< April 16, that the question of whether to publish a Federal

. Register notice was still up for discussion.  ;

. 4. Also on April 16, 1990, the EDO informed the Commissioners that the NRC4 staff would participate in the interagency reexamination of the KI issue and make

i. recommendations to the Commission on whether current KI i policy should be changed. Yet the trip report and viewgraphs suggest that the interagency group was presented
with the DPO panel's views, including the recommendation against any change in existing Federal. policy on KI, apparently as though they represented the agency's final policy position on the subject. I did not understand that '

i the DPO panel was in any position to speak definitively for

the agency -- especially in view of the fact that Eric j Beckjord had concluded on March 15 that the panel had failed i fully to resolve the DPO.

, 5. The EDO's April 16, 1990 memo to the Commissioners

] stated that Eric Beckjord's March 15 memo had found, as 4

noted in (4) above, that "some aspects of the DPO were not resolved by the review panel." (Mr. Beckjord was referring to the fact that the DPO panel had not addressed one of the

two main points of the DPO, i.e. that the Commission's 1983  ;

l policy decision on KI was based on inaccurate information 1

from the staff.) The EDO said: "The staff is working on

, their resolution as suggested by Mr. Beckjord." On this i point, I think the EDO may have been in error. I am not aware that any agency resources have yet to be applied to resolving the aspects of the DPO that Mr. Beckjord found in March to have been left unaddressed by the DPO panel.

I i The DPO process is supposed to provide a means to address concerns rapidly, especially when they involve health and safety issues. It is also supposed to provide a

definitive resolution, up or down, on issues that are raised. I do not see either of those goals being met in the

, more than fifteen months since I filed my DPO on potassium iodide.  ;

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4 39783 rederal Register / Vcl. 55. Ns. IN9 / Friday. Septmber 28, }s90 / N: tic:s 1

Ityo _

y I* would n5t reduce environmental Impacts of plant operation and would RTD/thermowell system mounted directly into the hot and cold lege of the Potasolumlodide result in reduced operational flexibility, reactor coolant system. Aotsscvt Nuclear Regulatory The application for the amendment Commission.

Alternotive Use ofResources His action does not involve the use of [q efta o e A mi Energy Act P ' "'

any resources not previously considered ended (the Act)* and the fbfe t nub 'at, kcause of in the Final Environmental Statements of1954, Comminion as am.a rulu and ngulauant ga new infonnecon. the analysis supporting the current federal policy Related to Operation of Perry Nuclear- Commission has made appropriate Power Plant. Units 1 and y. dated regarding the distribution and use of findings as nquind by the Act and the Potassium lodide (U) as a thyroidal August 1987*

Commission's rules and regulations in 10 blocking agent during accidents at Agencies andPersons Consulted CFR chapter L which are set forth in the nuclear power plants LE'being revised.

%e NRC staff reviewed the Ecensees. licase amendmet. Prehminary analysis cf this new request and did not consult other Notice of Consideration ofIssuance of information indicates that the cost.

agencies or persons. Amendment and Opprotuntry for Prior benefit ratio associated with stockpiling Headng in connecton with this action KI may have narrowed. As a result of Finding d No Significut imp *d was pubhsbed in the Federal Register on this new information and a request by The Commission has determined not June 14.1990 (55 FR 24172). No request the American Thyroid Association to to prepare an environmentalimpact for a hearing or petition for leave to establish a national stockpde of Kl. the statement for the proposed license intervene was filed following this notice. current federal policy regarding the a m nd a nt. De Commission has prepand an stockpihng and use of K1is undergoing a Based upon the foregoing Environmental Assessment related to reexamination.

environmental assessment, we conclude the action and had determined not to that the proposed action will not have a POR PURTHER HePORelaT10N COffraCTt Pnpare an environmentalimpact Leonard Soffer. Severe AccidentIssues significant effect on the quality of the statement. Based upon the humn avirommt. Branch. Office of Nucl ar Regulatory For further details with nopect to this avironmntal assusent. the Research. U.S. Nuclear Regulatory action, see the ap lication for Commission has concluded that the Commission. Washington. DC 20555 amendment date[ March 16.1990, which issuance of this amndment will not (301-492-3916).

have a significant effect on the quality is avadable for public inspection at the macuoRouwo:On July 24.1985 the Commission's Public Document Room, of the human environment.

2120 L Street. NW., Washington. DC and For further details with respect to the present federal policy (50 FR 30258) on at the Perry Public Library. 3753 Main action see (1)ne application for distribution of Potassium lodide (U) amendment dated April 12.1990, and around nuclear power sites for use as a Street. Perry. Ohio 44081.

supplemented by letter dated July 7. thyroidal blocking agent was issued. In Dated at Rockville. Maryland, this 20th day summary, the federal policy of September teso. 1990. (21 Amendment No. 57 to Ucense recommends the stockpiling of KI and its For the Nuclear Regulatory Commisolan. No. NPF-30. (3) the Commission's distribution for emergency workers and related Safety Evaluation dated Iohn N. Hannon, inattutionalized peruna, but does not September 20.1990, and (4) the Dimetor. Project Dimetomie M4 Divislan of Environmental Assessment dated recommend requiring predistribution or September 5.1990. All of these items are stockpiling for the general public. %e

[s. O[ce e e available for public inspection at the basis for this policy is that,in the event A,sulation, of an accident, protective actions are Commission's Public Document Room,

[TR Doc. 90-2sr71 Filed S-27-eat 8.45 am) Gelman Building 2120 L Street NW., planned and would be taken for the Washington. DC and at the Callaway general public that are capable of County Public Ubrary. 710 Court Street, reducing doses to all body organs. and (Docket No. 50 4431 Fulton, Missouri 65251 and the John M. not merely the thyroid gland. %1s policy W8 8 '

  • e whc c the he Union Doctric Co.tleeuence of g,'$ 0 s. ov Amendment tWMperating louis. Missourt 63130. A copy of itsma ts of their authority, take mearures
  • *"** (2). (3) and (4) may be obtained upon tayond those recommended or required nationally. In this regard, two states De U.S. Nuclear Regulatory request addressed to the U.S. Nuclear Commission (Commission) has issued Regulatory Commission. Washington. (Alabamd and Tennessee) have decided q to stockpile or predistribute KI tabiets 1 Amendment No. 57 to Facility Operating DC 20555. Attention: Director. Division License No. NPF-30, issued to the Union of Reactor Projects III. IV V and Special for use by the public in the event of a Projecta, serious reactor accident.

Electric Company (the licensee), which revised the Technical Specifications for Dated at Rockvilla. Maryland, this 20th day Since issuance of this pohey, nw operation of the Callaway Plant Unit 1 information ngarding KI has become of September isso, availabla. Information is now be: oming located in Callaway County. Missourt. Fw the Nuclear Regalatwy Comunisaloa.

%e amendment was effeceva as of the available on the experience during the date of issuanca. John N.Hannen. Charnobyl acddent in the Soviet Union De amendment modified the Dimetar. Proied Dimerosse 54 D/rision of in April 1986 where signiScant ,

Technical Specification Tables 2.3-1. AeoetarPro erse-5,lV. YandSpecial quantities of KI were adminletered by P 3.34, and 4.5-1 and associated Bases to ' Pm/scas. Office ofNuclearReactor Polish and Soviet authorities.

arrammodsta the replacement of the Assulac'on. Additionally, since completion of the current Resistance Temperatum (FR Doc. so-22r71 F11ed 647-ect ac46 am) original analysis in 1980 supporting the i Detector (RID) bypass system with an anAsse ones vue.ews federal policy (NUREG/CR-1433).

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Federal Register / Vol. 55 No.189 / Friday. SeptembIr 28,1990 / Notic:s 39789 4

j information has become available DEPARTMENT OF TRANSPORTATION of the Act and subpart Q of the

. Indicating a aeduction in todine releases Regulations, applies for a foreign air j associated with a severe reactor Aviation Proceedings; Agreements carrier permit authorizmg the carriage of I accident and a reduced cost and flied during the Week Ended property and mail on a scheduled basis increased shelf-life of KI. Preliminary September 21,1990 between a point or points in the analysis of this informationindicates Domincan Republic and Miami, Florida The following Agreements were filed

that the cost-benefit ratio which with the Department of Transportation and San Juan, Puerto Rico. Robiton also .

supports the current federal policy may under the provisions of 49 U.S.C. 412 requesta that it be granted authority to have narrowed from the 1980 analysisi and 414. Answers may be filed within 21 perate cargo charters subject to the ,

1 Further,in September 1989, days of date of filing. Department e rules and regulations.

i representativee of the AmericanThyroid Docket Numben 47183. Docket Numben 47180.

Association (ATA) requested that a Date filed
September 20.1990. Dat8 filed! September 19.1990.

j national stockpile of KI be established. Parties: Members of the International Due Datefor Answers. Conforming 4

In view of this request and the AliTransport Association. Applications, orMotion to Modfy availability of new information which

Subject:

Composite Resolutions R-1 to Scope: October 3,1990.

affects the underlying analysis, an effort R-21. D88Cription: Conforming Application to reexamine the federal policy on KI PmposedEffectiveDate April 1,1991. of America West Airlines,Inc., pursuant
has been undertaken. DocAet Numben 47184. to section 401 of the Act and subpart Q Acnymes unsoanWAY:The Nuclear Datefded: September 20.1990. of the Regulations requests a new or l

. Regulatory Commission (NRC)is Parties Members of theInternational amended certificate of public presently preparing an update of the Air Transport Association. convenience and necessity authorizing it i to provide service between Phoenix, original 1980 analysis (NUREG/CR- Sub/ect: Mail Vote 428-Fares from i

1433). The updated report will consider Ecuador to Central America. Arizona, Las Vegas, Nevada and Los the latest available research on PmposedEffective Date: October 1. Angeles. California, on the one hand, estunated iodine releases from severe 1990, and Mexi@, Mco, on the othw, reactor accidents, will incorporate the Docket Numben 47185. DocketNumben 47181.

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most recent estimates on risk to the Dalefiled September 20,1990. Date filed: September 19.1990.

thyroid from internal radiolodine Parties: Members of the International Due DatafotAnswers, Conforming exposure, and will factor in revised Air Transport Association. Applications, orMotion to Modify l

Subject:

Mail Vote 429-PEX fares Scope: October 3,1990.

values for cost and shelf life of KL This l report is expected to be issued by July from Japan to Southeast Asia. . Desenp~ tion: Conforming Application 4

1991 to state and local authorities and to Pmposed ffective Date: October 28. of United Air Lines. Inc., pursuant to

, the public. 1990. section 401 and subpart Q of the in parallel, as a result of the request ** * * ' "9"" * * * "'

i by the ATA to establish a national Gef &cumentasyServicesDivision. public convenience and necessity to

, stockpile of KL the Federal Radiological [G Doc. 90-22P10 nled 9-27-am t.45 am) rise se ce betwe eles.

Preparedness Coordinating Committee same case emes.es -

(FRPCC) has requested that the NM' O' i Department of Health and Human met &cumentaryservicerDivision.

Services, through the Centers for Noeceof Appucadonsformtes [m Doc so 22o20 Ned s-27-em 4:46am)

Disease Control (CDC) convene an ad of ubNc Convenience end U Q same caen ..es.

, hoc meeting of experta in this Bel 1 to anNgn & Carrier PermNs Red i solicit and review relevant scientific ndo N W W N M l information on this issue, and to provide Ended Seg=tomber 21,1990 [Decket No.479001

its recommendations to the FRPCC. The following applications for Accordingly, a workshop on the Unned StateeWnned Kingdom certificates of public convenience and Regional Airport Case No#ce of I scientiSc and medical aspects of KI was necessity and foreign air carrier permita Hearing i held in Atlanta on July 24,1990.The were filed under subpart Q of the review by CDC will consider the Department of Transportation's Notice is hereby given that the 3 available new information noted above. Procedural Regulations (See 14 CFR hearing in the above entitled matter will j The CDC is expected to provide its 302.1701 et. eeg.).The due date for begin at 10 a.tn. on October 9.1990 and recommendations to the FRPCC on answers, conforming application, or run for the necessary consecutive i

' whether the current federal policy motion to modify scope are set forth weekdays.The hearing site is in room should be reassessed by November 1990, below for each application. Following 5332. Nassif Building. 400 Seventh Should the FRPCC determine that the the answer period DOT may process the Street. SW. Washington, DC 20500.

federal policy warrants reassessment by application t y expedited procedures. Questions concerning this proceeding allinvolved federal agencies, an Such pmcedures may consist of the that require a telephonic discussion i associated schedule for accomplishing adoption of a show-cause order, s. should be telephoned to (202) 306-2144.

I this would be established. tentative order, or in approrpiate cases a Notice is also given thatin the event

! Deted at Rockville. Magland, this 21st da final order without further proceedings. that funding for the Department of of October m Docket Numben 47178. Transportation for Fiscal Year 1991 has j Data filed: September 17,1990. not been effected by the Congress by Mcs. neck} erd. Due DatefcrAnswers, Conforming October 4.1990, thereby (1) precluding Director. Ofin ofNuclearRegulatory Applications, orMotion toModify the timely procurement of a court ResearcA Scope October 5.1990.

4 reporter for the transcription of the (m Doc.80 22974 Ned 5-z7-em s.es am)

Description:

Application of Robitos bearing and/or(2) requiring the aume ones reme+e Aereo. C. Por A, pursuant to section 402 furioughing of Department employees j - -

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