ML20147H995
| ML20147H995 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1997 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-2097, NUDOCS 9704100070 | |
| Download: ML20147H995 (239) | |
Text
~
ACRST- 2697 Official Transcript cf Proceedings -
O NUCLEAR REGULATORY COMMISSION l
Title:
Advisory Committee on Reactor Safeguards ;
d40th Meeting ,
TRO4 (ACRS)
RETURN ORIGINAL i'
TO BJWHITE M/S T-2E26 Docket Number: (not applicable) 47g 4
i I Location: Rockville, Maryland
^
O Date: Friday, April 4,1997 ACRSTfceOb?y Refrii forze _"eiae Comi~::ee @L i Work Order No.: NRC-1071 Pages 165-279 g 41 g o 970404 T-2097 PDR
- NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers
.A 1 D g21 1323 Rhode Island Avenue, N.W. ..___.
.O Washington, D.C. 20005 'E~c e - -=->~wq (202) 234-4433 M J") 7 W r_ s_ u y / ,,
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b DIBCLAIMER PUBLIC NOTICE BY THE ,
UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS APRIL 4, 1997 4
The contents of this transcript of the proceedings- of the United States Nuclear Regulatory ,
Commission's Advisory Committee on Reactor Safeguards on APRIL 4, 1997, as reported herein, is a record cf the
}
discussions recorded at the meeting held on the above date.
This transcript has not been reviewed, corrected and edited and it may contain inaccuracies.
t e
I A
L.) I NEAL R. GROSS
- COURT REPORTERS AND TRANSCRiflERS 1323 R1IODE ISLAND AVENLT., NW 0 02)2344 43i WA$il!NOTON, D C. 20005 (202)234-4433 :
165 1 UNITED STATES OF AMERICA fS 2 NUCLEAR REGULATORY COMMISSION l )
%J 4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) 5 440th MEETING 6 + ++++
7 "RIDAY 8 APRIL 4, 1997 9 + ++++
10 ROCKVILLE, MARYLAND 11 +++++
12 The Advisory Committee met at the Nuclear 13 Regulatory Commission, Two White Flint North, Room T2B3, 14 11545 Rockville Pike, at 8:30 a.m., Robert L. Seale, 15 Chairman, presiding.
16 17 COMMITTEE MEMBERS:
18 ROBERT L. SEALE CHAIRMAN 19 DANA A. POWERS VICE CHAIRMAN 20 GEORGE APOSTOLAKIS NSMBER 21 JOHN J. BARTON MEMBER 22 THOMAS S. KRESS MEMBER 23 WILLIAM J. SHACK MEMBER 24 b)l N_ 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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166 l 1 ACRS STAFF PRESENT:
,-s 2 JOHN T. LARKINS Exec. Director t )
3 ROXANNE SUMMERS Tech. Secretary 4 SAM DURA 1SWAMY 5 CAROL A. HARRIS 6 RICHARD P. SAVIO 7 PAUL BOEHNERT 8 NOEL DUDLEY 9 MEDHAT M. EL-ZEFLAWY 10 MICHAEL T. MARKLEY 11 AMARJIT SINGH 12 13 ALSO PRESENT:
('
'- >~t 14 LAURENCE KOPP 15 MIKE JAMGOCHIAN 16 ALAN NELSON 17 ROY R. WIGHT 18 ABY MOHSENI 19 20 21 22 23 24 f
!s,
) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 234 4433 WASHINGTON, D C- 20005-3701 (202) 234-4433
167 1 A-G-E-N-D-A
,x 2 Aaenda Item Pace
( ,I w.- 168 3 Opening Remarks by ACRS Chairman 4
5 Boraflex Degradation in Spent Fuel Pool 6 Storage Racks 7 Thomas S. Kress 170 8 Laurence Kopp 172 9
10 Use of Potassium Iodide after a Severe 11 Accident 12 Michael Jamgochian 200 13 Alan Nelson 209 f3
- 14 Roy Wight 246 15 16 LUNCHEON RECESS 257 17 18 Preparation of ACRS Reports 259 19 20 21 22 23 24 (O,,,/ 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1*423 RHODE ISLAND AVE., N W.
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168 1 P-R-O-C-E-E-D-I-N-G-S v^x 2 (8:35 a.m.)
3 CHAIRMAN SEALE: The meeting will now come to 4 order. This is the second day of the 440th meeting of the 5 Advisory Committee on Reactor Safeguards. During today's 6 meeting the committee will consider the following:
7 (1) Boraflex Degradation in Spent Fuel Pool 8 Storage Racks; 9 (2) The Use of Potassium Iodide After a 10 Severe Accident:
11 (3) Future ACRS Activities; and 12 (4) Proposed ACRS Reports.
,_ 13 This meeting is being conducted in accordance !
14 with the provisions of the Federal Advisory Committoe Act.
l l
! 15 Dr. Sam Duraiswamy is the designated federal 16 official for the initial portion of this meeting.
l 17 Members present include George Apostolakis, l
18 Tom Kress, Dana Powers, John Barton, Bill Shack, and 19 myself, Robert Seale. Absent are Dr. Mario Fontana and 20 Dr. Don Miller.
21 We have received written comments from Mr.
22 Peter Crane concerning the item on the use of potasaium
, 23 iodide after a severe accident. These comments have been I
24 distributed to the members and will be made part of the O
(_,/ 25 record of today's meeting.
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169 1 We have also received requests from the
,3 2 Nuclear Energy Institute and the State of Illinois to make
(] 3 oral statements regarding the item on the use of potassium 4 iodide after a savere accident.
5 A transcript of portions of the meeting is 6 being kept, and it is requested that the speakers use one 7 of the microphones, identify themselves and speak with 8 sufficient clarity and volume so that they can be readily 9 heard.
10 I would remind you again, that today at noon 11 beginning -- we will recess at about 11:30 -- no, about 12 11:45, and beginning about noon Mr. John Szabo with the 13 office of the General Counsel will be here to respond to O
\/ 14 questions that members have regarding conflict of interest 15 questions and other issues like that.
16 I would urge you to craft any questions you 17 have very carefully so that we are sure that the questions 18 that we present to him completely represent the 19 circumstances that have caused some of us questions and 20 concerns in the past.
21 Are there any other initial remarks at this 22 time? We have two letters this morning and we have a 23 possibility after the members have a chance to look at it, 24 of a draft ca a letter on 50.59 issues that we heard
,r'N
( ,) 25 yesterday afternoon.
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170 1 We will try to finish by the end of the day;
,s 2 we're committed to do that. And so I would urge everyone
( !
3 to be on their most constructive behavior.
4 If there are no other questions or information 5 items at this time, the first item has to do with Boraflex 6 degradation. The subcommittee chairman on that is Dr.
7 Kress. Tom?
8 MEMBER KRESS: Thank you, Mr. Chairman. The 9 regulations call for a 5 percent margin to criticality in 10 the spent fuel pools. That's a .95 Kser for you physicists.
11 And one way this is accompliched is the inclusion of B.C in 12 the form of something called Boraflex, into the storage 13 racks.
(A)
N' 14 Boraflex is a mixture of a silica and a 15 polymer in B 4C, and it's generally held in stainless steel 16 that's tack-welded to the racks themselves. During 17 removal of surveillance coupons -- going back I think, 18 into the mid '80s or earlier -- it has been observed that 19 Boraflex in these surveillance coupons, when exposed to 20 tha cool water, degrades.
21 That is, it loses mass. And presumably this 22 mass is somewhere; it goes into the water and maybe into l l
23 the filters that clean the spent fuel pool. And this l
24 problem t.en 5 was studied by EPRI and they concluded that i
/N
(_) 25 the degradation was due to a combination of the gamma !
l
>HDAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 HHODE ISLAND AVE., N W.
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I
171 1 1 irradiation and the exposure to the water. Whether that's
~s 2 a chemical effect or a dissolution is not clear.
( I s
3 So the question is, is this degradation about 4 to compromise this'5 percent margin that's required by the 5 regulations? So the issues are: what are the conditions 6 of the pools at the various plants -- the conditions the 7 Boraflex; how much degradation have they experienced, if 8 any, and is this 5 percent margin being challenged at all; 9 and if so, the feeling that this is so, what are the 10 possible fixes?
11 So the staff I think, las written both the 12 information notices and generic letter on this, and I 13 think have plans to revise the regulations and the
/, i
~Y 14 standard review plan related to spent fuel pools. The 15 generic letter asked the licensees to assess their 16 condition and report back with any planned fixes, if I
17 needed.
18 So today, what we're going to have sa 19 briefing on the status of all this. And with that 20 introduction I'll turn it over -- if I didn't do too much 21 damage to your presentation.
1 22 VICE CHAIRMAN POWERS: Tom, do we know what 23 the polymer is?
24 MEMBER KRESS: Yes, it's a polymeric methyl t's 1
(_) 25 something-or-other -- they know what it is.
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172 1 VICE CHAIRMAN POWERS: Well, polymeric methyl 2 something-or-other, it makes a difference. And do we know 7s
~'
3 what the cose -- accumulated dose these things are 4 receiving is?
5 MEMBER KRESS: Of course, that relates on the 6 pool and --
7 VICE CHAIRMAN POWERS: Sure.
8 MEMBER KRESS: It's pool-specific, and they 9 have ways to estimate that. But I think he'll get into 10 these details.
11 MR. KOPP: Good morning. My name is Larry 12 Kopp. I'm with the Reactor Systems Branch, NRR, and I 13 plan to address first of all, how Boraflex is used in i i
'/ 14 spent fuel pool racks, and then some of the regulatory 15 issues that are currently involved.
16 We had planned to have Dr. Odelli Ozer from 17 EPRI here today to supplement the talk with current EPRI 18 R&D programs. Unfortunately, there was a scheduling 19 conflict; he couldn't make it. But he said that if the 20 staff would like him at some future date, ha'd be glad to 21 come down and give a presentation.
22 During the initial design of current nuclear 23 power plants, the onsite spent fuel storage facilities 24 were designed for temporary storage of irradiated fuel in p)
\ _
25 the water-filled pools before shipment to reprocessing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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173 1 plants; therefore, there were no storage capacity 2 concerns.
(]
s_e 3 And the suberiticality of the stored 4 assemblies was achieved by the relatively large center-to-5 center spacings, on the order of 21 inches, which 6 neutronically decoupled, one assembly from the other.
7 However, when the reprocessing plants were 8 cancelled and when the central repository was delayed, 9 onsite -- site fuel assembly storage capacity concerns 10 arose. So in order to achieve sufficient storage 11 capacity, many plants removed the original storage racks 12 and replaced them with racks containing various neutron-
',_s 13 absorbing materials inserted around the assembly storage i
'~' 14 cells.
15 This allowed a much smaller center-to-center 16 spacing, a significant increase in the number of 17 assemblies which could be stored in the same storage 18 facility, and therefore these racks became known as high-19 density spent fuel storage racks.
20 Thic is a typical design of what a storage 21 rack looks like. \nd the dark areas around the sides are 22 the neutron-absorbiny material, and in many cases it's 23 Boraflex; other cases .aorated stainless steel is used; and 24 still in other cases, bo.ated aluminum, or boral, is used.
(_,/ 25 And the Boraflex is neutron-absorbing material NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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174
)
1 composed of silicon, rubber, and it's impregnated with 2 boron carbide. And if you see -- the consistency of the 3 borax before it's irradiated is somewhat like a rubber 4 band. After irradiation it looks like a piece of metal --
5 sheet metal.
6 VICE CHAIRMAN POWERS: is there a particular 7 advantage to using this Boraflex rather than the borated 8 steel?
9 MR. KOPP: I think the advantage may have been 10 price-wise -- price advantage. We tried to determine why, l 11 back in the, I guess it was in the early '80s it was first I
l 1 i
12 used, and saw no real reason except maybe price-wise. l 1
13 VICE CHAIRMAN POWERS: Fabrication --
(~h 1 i j i '
k' 14 MR. KOPP: As far as reactivity hold-down l 1
l 15 there's no -- l'
(
16 VICE CHAIRMAN POWERS: There's no advantage of l
l 17 one over the other? )
18 MR. KOPP: No advantage, no. It may be easier I 19 to handle also, since it is flexible rubber. It can just l
20 be put on the stainless steel and covered.
21 Here's an outside view of what a typical 22 storage cell looks like. And the Boraflex is inside this 23 sheeting which is stainless steel, and it's usually tack-24 welded around the sides and there are vent holes to vent
,m.
() 25 the off gases that are produced when Boraflex undergoes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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175 And unfortunately that leads to one of the l 1 radiation.
73 2 problems -- by allowing water to come into contact with )
N~'
3 the Boraflex, as I'll mention a little later. !
4 Experimental studies have shown that, for a 1
5 long time, that Boraflex will shrink during gamma I 6 radiation. Tests have sl own that there's a maximum 7 shrinkage threshold of about 4 percent, beyond which no 8 further shrinkage occurs. And that threshold usually 9 occurs at about -- an accumulated gamma dose of about 10" 6
10 rads.
11 Many storage racks accounted for that 3 I
12 shrinkage by manufacturing the Boraflex a little longer 13 than the active fuel length so that as it did shrink it ,
/) I
\~ l 14 would still cover the fuel length. However, in the mid-15 '80s, gap formation in the Boraflex was discovered. And i
)
16 that was reported by the NRC in Information Notice 87-43. l l
17 The gap occurs when the Boraflex is irradiated l l
18 and is not free to shrink. Here's a typical non- J 19 irradiated Boraflex panel, about 12 feet in length, 5 to 20 70 inches wide, and usually about .025 to .125 inches ;
I 21 thick. As it undergoes irradiation and it's free to 22 shrink, it shrinks a maximum of about 4 percent, top and ;
l 23 bottom and width-wise.
24 But if for some reason it's constrained at the p
( 25 top and the bottom, either due to tight tolerances or NEAL R. GROS $
COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W. l (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 )
176 1 maybe the tack welding or adhesives, it's not free to
,s 2 shrink and it just snaps apart and forms these so-called i'~'/ 3 gaps. And the gaps vary, actually, all over the place.
4 They're not uniformly distributed along a midplane.
5 MEMBER KRESS: Shrinking is an interesting 6 process. Does it involves loss of mass?
7 MR. KOPP: No. No, that's --
8 MEMBER KRESS: Just increasing in density, is 9 that what's happening?
10 MR. KOPP: Right, right. And that's not 11 accounted for in the analysis, so even though -- it snaps 12 apart, of course the area here and here probably become 13 more dense as far as containing boron, but that's not O
'-s/ 14 included usually in the criticality analysis.
15 MEMBER KRESS: Is it understood how gamma 16 radiation increases density in this stuff?
17 VICE CHAIRMAN POWERS: I think probably -- my 18 guess is that what's happening is that you're breaking a 19 bond in the material crosslinks and that creates a higher-20 density polymer.
21 MEMBER KRESS: It's the polymer you're working 22 on?
23 VICE CHAIRMAN POWERS: Yes, that you just get 24 chain-to-chain bonding, pull the chains together and get a
/~N is ,) 25 higher density.
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177 1 MEMBER KRESS: That would make sense.
2 VICE CHAIRMAN POWERS: And that's typically
\
x '~')
3 what happens in polymers when they're -- they get dosed 4 is, that you just get crosslinkage. And there's some mass 5 loss. I mean, you lose something, usually --
6 MEMBER KRESS: That must be peculiar to 7 polymers because --
8 VICE CHAIRMAN POWERS: Oh, yes.
9 MEMBER KRESS: -- practically all other 10 materials swell when they're irradiated.
11 VICE CHAIRMAN POWERS: Yes, but this is, very 12 definitely, a polymeric phenomena.
13 MR. KOPP: Unfortunately, our chemical
(~N.
- t
'# 14 engineering department is following this, but he is on 15 travel this week. Licensees have accounted for this 16 shrinkage and gap formations in their criticality 17 analyses, and have taken -- have found that the reactivity 18 effects are generally small enough so that they can be 19 readily accounted for in the existing design basis of the 20 storage racks.
21 There's a procedure called blackness testing 22 that has been used to determine whether gaps exist and if 23 so, how big they are, and it's just a matter of -- if one 24 has a series of storage cells and Boraflex around this es.
', ,) 25 cell, a device is actually transversed down the storage NEAL R. GROSS
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178 1 cell. These other cells have to be vacated of fuel.
r's 2 And this device consists of a neutron source (v) 3 and also four neutron detectora in the same piece of s
4 equipment. And the fast neutrons are sent out to the 5 surrounding racks or spaces, they're thermalized in the 6 water, and either absorbed in the water or reflected back 7 where they're detected by the neutron source in this 8 apparatus.
9 Now, if there's no Boraflex loss here nothing 10 is detected -- or essentially nothing is detected at the 11 neutron detector. If there is a gap, all of a sudden 12 you'll see a blip. And by comparing that trace with a 13 standard, they can determine how much the Boraflex gap has
'd' 14 expanded.
15 That was the shrinkage and gapping problem.
16 More recently there has been a second factor that could 17 affect the storage rack service life, and that's the 18 potential, gradual release of silica, which is filler 19 which are in Boraflex.
20 Following gamma radiation and long-time 21 exposure to the wet pool environment, we saw in the 22 manufacturing of the racks that there are openings for gas 23 venting, and also there are probably openings around the 24 side where the stainless steel plate was tack-welded
()
,m 25 around the Boraflex.
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179 1 So the amount of water that gets into the e3 2 racks is dependent on the manufacturing of how the racks (m) were put together, so it varies from plent-to-plant.
3 4 When Boraflex is subjected to gamma radiation 5 in the pool's wet environment, the silicon matrix becomes 6 degraded and silica filler and boron carbide are both 7 released. Since the irradiated Boraflex typically 8 contains about 45 percent of silica and 50 percent of 9 boron carbide by weight, the presence of silica in the 10 pool water indicates the likely depletion of the boron 11 carbide from the 3oraflex.
12 MEMBER KRESS: Do those numbers mean that 13 there's only 5 percent of this polymer in that? It seems
() 14 awful strange it can get that much' shrinkage with just 5 15 percent polymer, Dana.
16 MR. KOPP: Those are the weight percentages 17 after the radiation --
18 MEMBER KRESS: I wouldn't have thought silica 19 would have shrunk, and I wouldn'C have thought B.C would 20 have shrunk.
21 VICE CHAIRMAN POWERS: Not under irradiation, 22 you're not going to get --
23 MEMBER KRESS: That's what I'm talking about; 24 under irradiation. So you're left with 5 percent of the
(
/)T 25 whole material is this polymer. Seems a little strange --
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180 1 VICE CHAIRMAN POWERS: It seems like an e 2 awfully low fraction of --
[S A, '/
)
~
3 MEMBER KRESS: The numbers seem a little 4 strange'to ma. I don't --
5 VICE CHAIRMAN POWERS: I can't really comment.
6 MEMBER SHACK: Well, that's a weight percent 7 rather than a volume percent, but it's still --
8 VICE CHAIRMAN POWERS: Yes, but none of the 9 things are very dense here. I mean, silica runs what, 10 three or so, and the boron carbide is like, one, and the 11 polymer is like, one, so there's not a huge density 12 difference here.
13 MR. KOPP: In the early-1980s, several plants p.
G 4
\/ 14 which contained Boraflex reported that there were elevated 15 amounts of silica in the spent fuel pool water; indicated 16 that there was Boraflex degradation occurring. And the 17 NRC then issued Information Notices Number 93-70 and 95-38 18 to alert licenses of this new Boraflex concern.
19 MEMBER KRESS: This is two different 20 Information Notices, two years apart?
21 MR. KOPP: Yes. I think one was issued because 22 it occurred in surveillance coupons, also degradation.
23 And the second one was issued when it was actually 24 observed in a rack itself, in the full Boraflex.
g
() 25 Several factors that affect this dissolution
'NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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181 1 of Boraflex. One is the access of water to and around the es 2 Boraflex, and that's probably the most significant factor.
('~' )
3 And that of course varies from rack-to-rack depending on 4 how the rack was manufactured, how the stainless cover was 5 put over the Boraflex, and how much -- that determines how 6 much water can get into the -- actually touch the 7 Boraflex.
8 The rate of dissolution also increases with 9 higher pool temperatures. This of course suggests that 10 pool temperatures should be kept as low as practical.
11 And of course the accumulated gamma exposure 12 is another factor that increased the rate of dissolution, 13 and therefore EPRI has suggested that freshly discharged KJ 14 fuel assemblies after each unloading should not be put in 15 the same area of fuel racks, but sort of distributed 16 around so that -- distribute the total of gamma 17 accumulation.
18 And because Boraflex is used in the spent fuel 19 pool racks for non-productive absorption of neutrons, a 20 reduction in the amount of Boraflex could result in an 21 increase in the reactivity of the spent fuel pool 22 configuration. And staff is concerned that this may 23 approach or even exceed the current NRC acceptance 24 criterion, which is Kerr shall be no greater than .95.
I
) 25 This 5 percent of criticality margin was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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182 1 developed by the staff for many years to meet the GDC 62 73 2 requirement that requires subcriticality in all fuel
\ )
v 3 handling and storage areas.
4 There have been several corrective actions 5 that have been proposed and many have also have been used 6 to account for any reactivity increase due to the Boraflex 7 loss. Many licensees have taken credit for the reactivity 8 decrease associated with fuel burnup, and have restricted 9 storage patterns therefore, to some type of checkerboard 10 array.
11 Others have used absorber rods. This will 12 work for of course, PWR assemblies that have holes where 13 control rods fit during the operation. Boilers,
(',) 14 unfortunately, don't have those rods throughout the fuel 15 assembly. So for PWRs there have been several instances 16 where poison inserts were incorporated in the control rod 17 channels of the storage assemblies.
18 The NRC has also recently approved the 19 methodology by which credit could be taken for some of the 20 soluble boron in PWR pool water. Most plants have between 21 2,000 to 3,000 ppm of a boron in the pool water, and to 22 meet the .95 it has been found that maybe 500 or so ppm 23 would be needed.
24 And therefore the staff has found this to be (O)_,
25 acceptable -- the very small portion of the amount of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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183 l
1 boron that's typically in there -- but we also require for !
fS 2 that methodology, licensees to do a boron dilution l
(J 3 analysis, which it was not required in the past.
4 MEMBER KRESS: I notice your previous slide on 5 'the regulation, it says that . 9 5 Key, was in case you're 6 flooded by non-borated.
7 MR. KOPP: Right.
8 MEMBER KRESS: Do you have to change that rule 9 --
10 MR. KOPP: Yes.
11 MEMBER KRESS: -- to get this --
12 MR. KOPP: Yes. There are two criteria now 13 that would come up. One would be less than one sorted by
\
' ') 14 non-borated water, and the second one would be less than 15 .95 with credit for a small round of boron.
16 MEMBER KRESS: Is that a new rule --
17 MR. KOPP: That's the new methodology that we 18 recently approved, that Westinghouse had submitted and was 19 modified slightly by CRGR when it went to the CRGR 20 committee. And there has been a lead plant that has come 21 in already where we're reviewing right now. And several 22 others are going to be using this to take care of part of 23 the Boraflex prob)em.
24 And additionally, Westinghouse has also 73
(_,) 25 suggested that if the committee would like to hear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1r3 RHODE ISMND AW., N W.
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184 1 something about that methodology, they'd be willing to e3 2 come in and speak to the committee.
I 1
- /
3 MEMBER KRESS: Yes, I think we've received a 4 report on it. Might be something we'd want to think about 5 hearing about.
6 MR. KOPP: As I said, most of these initial 7 corrective actions can't be used in BWRs, but there have 8 been recent demonstrations of absorbers, shaped sort of as 9 a chevron, that can be inserted while these fuel 10 assemblies are stored in the spent fuel pool.
11 Actually inserted around them to make up for 12 the Boraflex that may be missing. And EPRI is part of the 13 -- is a undevelopment of that and they're testing that out (3
- V 1
14 in several plants now. And that of course, will be 15 applicable to both PWRs and BWRs.
16 This is what we just spoke about -- how the 17 current NRC criterion would change. This is -- the 18 proposed criterion is what has been accepted as the 19 methodology, so that's now an accepted criteria. So our 20 old criterion of less than .95 when flooded with unborated 21 water with 95/95 probability confidence --
22 MEMBER KRESS: This requires an uncertainly ,
l 23 analysis? l l
24 MR. KOPP: Right, yes. Mainly on the
,e t
v
! 25 methodology -- certainly in the methodology and biases, ]
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185 1 and also on the manufacturing tolerances to two criteria:
,g 2 Kerr less than one, or suberitical when flooded with
\ ')
'~
nonborated water -- also at 95/95 confidence level; and 3
4 the second criterion now would be to meet the .95 5 criterion when flooded with borated water of a small 6 fraction of the total amount of boron that's in the spent 7 fuel pool.
8 MEMBER KRESS: The first one is in case you 9 get -- spring a leak in the pool and have to replace it 10 suddenly, the water -- fresh wecer -- to keep it covered?
11 MR. KOPP: Well, there's some conflicting 12 thoughts about that. If you start losing the borated 13 water and start uncovering the fuel, that's more of a Y-- 14 safety significance than a criticality concern.
15 MEMBER KRESS: So you want to put water over 16 it?
17 MR. KOPP: Well, yes. I 18 MEMBER KRESS: Ana you probably don't have 19 borated water available.
I 20 MR. KOPP: And to lose so many hundreds of j 21 thousands of gallons in unborated water without knowing I 22 it, seems to be a little strange.
23 MEMBER KRESS: A little hard to swallow, isn't ;
l 24 it? I
/"%
( ,) 25 MR. KOPP: In any event, we still are NEMLL R. GIUDSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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186 1 requiring the licensees to come in with the boron dilution s 2 analysis to tell us what the worst dilution event could
( 4
'~
3 be, and then there's sufficient time to isolate it and 4 correct it and make up the lost water.
5 MEMBER KRESS: Is there any plans for risk 6 analysis to see what the probabilistic risk is?
7 MR. KOPP: You mean if there were an actual 8 criticality event due to dilution?
9 MEMBER KRESS: Yes, postulate a sequence or 10 two and determine the probability.
11 MR. KOPP: There was a Westinghouse report 12 that was sent in for information only, where they did a 13 PRA analysis. We didn't really review that; it was just
\ ;
14 sent in for our information. And I think they came up 15 with results that were somewhat less than lo' for a 16 composite plant.
17 MEMBER KRESS: For a release --
18 MR. KOPP: For a dilution event that would --
19 MEMBER KRESS: A lesser frequency?
20 MR. KOPP: Right, yes. Yes, as far as what 21 the consequences are, dilution of --
22 MEMBER KRESS: Well, if it 's below 10-6 you're 23 probably within the guidelines of the large release 24 syndrome -- frequencies that low.
( ,) 25 MR. KOPP: Because of all these problems that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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187 1 had arisen with Boraflex, the NRC issued a generic letter
-s 2 in which all licensees that did have racks which contained V 3 Boraflex were requested to provide an assessment of the 4 physical condition of the Boraflex -- including any 5 deterioration on the basis of the current accumulated 6 gamma exposure and possible water ingress to the Boraflex 7 -- and to state whether the subcritical margin of 5 8 percent could still be maintained for the racks.
9 All licensees were further requested to submit 10 to the NRC a description of any proposed actions to 11 monitor or to confirm that this 5 percent subcriticality 12 margin can be maintained for the lifetime of the racks, 13 and to describe what corrective actions can be taken in
'- 14 the event that it couldn't be maintained.
15 Licensees were also asked to describe the 16 results of any previous post-operational blackness tests 17 and to state whether blackness testing or other types of 18 tests or measurements will be periodically performed to 19 ascertain the condition of the Boraflex.
20 Also, chronological trends of the pool silica 21 levels were also asked for along with the timing of 22 significant events such as refuelings, pool silica 23 cleanups, and so forth, and then an estimation of whether 24 silica buildup was occurring and possible Boraflex
(_j 25 degradation was occurring, could be evaluated.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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188 1 Responses to the generic letter indicated that y 2 most licensees were meeting the current 5 percent margin.
i :
ci 3 There were several licensees that stated they may not be 4 meeting the margin and are using temporary administrative 5 controls until they resubmit an analysis.
6 MEMBER KRESS: What are those controls?
7 MR. KOPP: Well, one of them is to make sure a that there's at least 2,000 ppm at all times in the pool 9 water by reducing the surveillance to maybe hourly -- to 10 every shift, or at least once a day. And with 2,000 ppm 11 of baron it turns out that you can lose all of the 12 Boraflex and you'd still have a well over 5 percent 13 subcritical margin.
i )
\/ 14 They're continuing surveillance through either 15 boron coupon surveillance programs, the blackness tests 16 that recently measured --
17 MEMBER KRESS: The boron that they put --
18 sizable boron in water -- is that boric acid?
19 MR. KOPP: Yes.
20 CHAIRMAN SEALE: Is there an identifiable 21 difference between dissolved boric acid boron, and 22 Boraflex degradation boron, if you will? I mean, is it an 23 oxide or whatever it might be? Can you chemically tell 24 the difference between the two?
,~
_, 25 MR. KOPP: I can. Well, I guess it would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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189 1 B 4 C for Boraflex.
2 MEMBER KRESS: Yes, B 4 C is pretty stable.
3 MR. KOPP: B C would be in the form of either 4
4 hunks or powder or something. Would probably just fall to 5 the bottom of the pool.
6 CHAIRMAN SEALE: Unless it oxidizes for some 7 reason.
8 VICE CHAIRMAN POWERS: What will happen is 9 that it will surface oxide but that's like real slow.
10 CHAIRMAN SEALE: Okay. So that boron is not a 11 significant overlay on the dissolved boron that's in the 12 borated water.
13 VICE CHAIRMAN POWERS: Probably pretty
'v) 14 insignificant.
15 CHAIRMAN SEALE: Okay.
16 VICE CHAIRMAN POWERS: I mean, it clearly 17 happens and you start picking up a little boron, but they 18 can't tell the difference.
19 CHAIRMAN SEALE: Okay.
20 MR. KOPP: EPRI also has mentioned a new type 21 of -- of course the blackness test really is not adequate 22 to determine Boraflex thinning, which is what seems to be 23 happening now with this newer phenomenon. The blackness 24 test is either a go/no go situation. There's either (g) 25 Boraflex there or chere's no Boraflex there.
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- - . .. . - .-. . - ~ . - . , . - . . . - - . . - - .
190 _;
1 EPRI has developed'a routine, ~a new device :
=2 which they call BADGER,_which they're testing out now to l O 3 determine, actually how much thinning has occurred'in a_
i l
4 Boraflex. panel. And it's somewhat'the same technique as 5 the blackness testing except the neutron source goes down 6 into one assembly and the det'ectors are-in the next 7 assembly; So that.you actually see the transmission -- !
8 raeasure the transmission rather than the reflection back. ;
b And the. fast neutrons are first slowed down i
)
i 10 here and reflected through the Boraflex. And comparing ,
j
-11 that trace with known standards they can determine how f i
12- much thickness of Boraflex has been lost. And I think ;
F 13 that's been tested out in a BWR as far as ~ know, and in l
-14 January they were supposed to have been testing it at a 15 PWR. !
MEMBER BARTON: How often are licensees !
16 17 required to do this test? l 18 MR. KOPP: We have no requirement for them on l 19 -- those that do it are doing it just to -- well, either j t
20 to verify that they meet the statements that we asked for 21 in the generic letter, or just that they meet their design i t
22 basis.
23 And as an indication of how many pools do have ;
i 24 Boraflex, there are 41 PWRs that contain Boraflex -- ,
25 including the two shutdown plants: Rancho Seco and NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W. 1
- (202) 234-4433 WASHINGTON, D C. 200054701 (202) 234-4433 i l
191 1 Trojan. And there are 13 boiling water reactors that fS 2 contain Boraflex in storage racks.
('~') 3 MEMBER KRESS: I presume when a plant shuts 4 down and undergoes decommissioning, that it will have to 5 continue this surveillance.
l 6 MR. KOPP: As long as the fuel is still there, [
7 right. Yes. Select and maintain the boron in the pool 8 water too. And unfortunately I was planning on having 9 EPRI here to discuss what's currently going on as far as i
R&D, but they couldn't make it. i 10 11 ' CHAIRMAN SEALE: In connection with R&D, have 12 you or do you know of anyone, who's tried to keep track of 13 the program that the French have on fuel behavior, fm c )
V 14 including things like subcriticality and storage and l 15 burnup effects and so forth?
16 The French have a criticality laboratory at 17 Valduc where they have done a series of measurements over 18 the years, including simulated burnup poisons, and 1
19 measured Kerr or K infinities for that material. And this 20 work is being done for COGEMA, which is their fabrication, 21 fuel element, sales outfit.
22 And I guess most recently, the U.S. has had 23 some access to the results of sorts of these experiments.
24 They have a new campaign going on now where they're p
C) 25 extending the simulated burnup on these elements into the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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192 1 high burnups region -- 65,000 -- things like that.
2 And as I have heard, the willingness to share (y
() 3 or trade information that they have, recently has become a 4 lot more open. And I would be surprised if they haven't 5 had, as a part of that, considerations like this -- the 6 degradation of Boraflex or whatever they do similarly in 7 France -- and you know, I guess I would urge that you 8 might want to see if you can open up that line of 9 communication.
10 Because if they've been doing it, at least 11 they've got that much time already invested in it, and 12 time is an essential part of any kind of degrada't' ion 13 measurement process. So if you could get access to that
-I 14 information -- and you may have some things that you'^,e 15 done that you could trade with them -- you know, they' 16 don't care for money so much as information --
17 MR. KOPP: Good.
18 CHAIRMAN SEALE: And it's an area of 19 international cooperation where there has to be a lot of 20 mutual interest; that you might want to develop it.
21 MR. KOPP: Our fuels people might already be 22 aware of that an --
23 CHAIRMAN SEALE: I don't know, but you might 24 want to inquire --
q,/ 25 MR. KOPP: -- as far as the burnup issue NEAL R. GROSS l
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193 1 because --
r~~x 2 CHAIRMAN SEALE: Yes.
't.
3 MR. KOPP: I'm not sure if any --
4 CHAIRMAN SEALE: If you want to know more 5 about that Lab, I visited there recently and I'll be glad 6 to fill you in on it.
7 MR. KOPP: I'm not sure if any foreign 8 countries use Boraflex or whether it's just used in the 9 United States.
10 CHAIRMAN SEALE: Well that's, you know, that's 11 another issue to try to --
12 MR. KOPP: Yes.
13 VICE CHAIRMAN POWERS: I'm going to ask
( ) something you may well not know anything about: is the 14 15 economics of doing all this testing versus pulling the 16 racks out and putting some borated steel on them or boral 17 on them.
18 MR. KOPP: Well, there's several concerns.
19 One of the concerns is a lot of these racks are completely 20 filled up. These pools are filled up and there's nowhere 21 to off-store --
22 VICE CHAIRMAN POWERS: No place to put the 23 fuel --
24 MR. KOPP: -- put your rack in.
/7 l
(_ ,/ 25 VICE CHAIRMAN POWERS: That's right, you can't NEAL R. GROSS COURT REPORTERS AND TRANSCRISERS 1323 RHODE ISLAND AVE., N W.
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194 1 pull one --
2 MR. KOPP: And they can't -- some of them wait 73 b 3 five or ten years for the fuel to cool down and they can 4 put them in the dry storage casks, and in that case they 5 can re-rack. But others are just so loaded that --
6 VICE CHAIRMAN POWERS: And they can't just 7 drop a thin can wall down? A shim?
8 MR. KOPP: Well, that's one of the things that 9 EPRI has developed now, that rack saver -- the chevron 10 thing that -- it can go right down over the storage fuel 11 assembly.
12 VICE CHAIRMAN POWERS: Seems like a lot 13 simpler just to change materials than it is to go do
-) 14 surveillances for the rest of your life.
15 MR. KOPP: Of course, we're still waiting for 16 the repository.
17 VICE CHAIRMAN POWERS: That's like waiting for 18 it to snow. Your life is not to long.
19 MEMBER KRESS: Does NRC have a code it uses to 20 calculate K e rr for audit purposes for these -- what is it, 21 KENO? Is that what the --
22 MR. KOPP: KENO -- yes, recently one of our 23 junior members has done some KENO calculations for us.
24 Apparently it can be used now on a PC, which amazed me.
A 4
(_/ 25 Last time I ran codes I had big decks of punched cards and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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195 1 big rooms with --
2 MEMBER KRESS: Be careful, you're going to
(.) 3 date yourself.
4 MR. KOPP: Well, actually, it was 32 years ago 5 today that I came here.
6 MEMBER KRESS: Yes, we forgot to ask him the 7 Jay Carroll question.
8 VICE CHAIRMAN POWERS: Oh, we really ought to.
9 MEMBER KRESS: We really ought to, yes.
10 VICE CHAIRMAN POWERS: He gave such a nice 11 presentation.
12 MEMBER KRESS: Yes, it was a very --
13 VICE CHAIRMAN POWERS: We want you to come rx
/ )
\-) 14 back. ,
15 MEMBER KRESS: The Jay Carroll question is for 16 people we haven't had much interaction with and don't 17 really know on the staff usually is -- why is it you think 18 you're qualified to come and talk on this subject to this 19 committee?
20 MR. KOPP: I was the only one here today.
21 MEMBER KRESS: It's a way of asking what -- a 22 little bit about your background and training and stuff 23 is. Just so we get to know you.
24 CHAIRMAN SEALE: He knows how to drop the (3
( ,) 25 letter back to your pocket.
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196 1 MR. KOPP: I graduated -- I got my bachelor's degree in Physics in New Jersey from Fairleigh Dickenson (o )
2
~
3 and went to work for the Curtis Wright Nuclear Division, 4 which subsequently moved to Quihanna, Pennsylvania, and 5 then went out of business.
6 Left them and went to -- did some programming 7 for a couple of years in New Jersey with a Division of 8 IT&T, and in late '59 I went with the Martin Company 9 Nuclear Division for four-and-a-half years until they 10 folded up.
11 After that I went to Westinghouse Astronuclear 12 which lasted for a few years and went on their -- when 13 they lost the Minerva contract. And I've been here ever 14 since; since '65.
15 MEMBER KRESS: Well, it was a very good 16 presentation, very informative and well done, and we want 17 to thank you for that; for coming down and spending the 18 time with us.
19 MR. KOPP: Thank you. And as I said, if you'd 20 like to hear more from EPRI as to the current R&D 21 programs, they'd be glad to come down and speak to you.
22 CHAIRMAN SEALE: And if things develop that 23 you think we ought to hear about, we'd appreciate a high 24 sign. Noel is your contact.
(3,
() 25 MR. KOPP: Thank you.
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197 1 MEMBER KRESS: With that, Mr. Chairman, I'll g
x, 2 turn the floor back to you.
lv! 3 CHAIRMAN SEALE: Well, goodness, let's see.
4 We are an hour early. So I would suggest that --
5 VICE CHAIRMAN POWERS: I could use some 6 advice.
7 CHAIRMAN SEALE: Okay, I was going to say, 8 we'll want to wait until 10:15 since we have so many 9 others who have indicated an interest and desire in 10 participating in the potassium iodide presentation.
11 (Whereupon, the foregoing matter went off 12 the record at 9:20 a.m. and went back on 13 the record at 10:19 a.m.)
I i
\# 14 CHAIRMAN SEALE: At this point we have to 15 consider the question of tne use of potassium iodide after 16 a severe accident in a nuclear power plant. The 17 background on this particular subject is somewhat complex, 18 but more importantly I think, a little bit different than 19 some of the things we normally consider. And I'd like to 20 make sure that we all understand that.
21 In 1989 a member of the Office of the General 22 Counsel filed a Differing Professional Opinion requesting 23 a re-evaluation of the NRC policy regarding the use of 24 potassium iodide after a severe accident at a nuclear
,x, k, s 25 power plant. In SECY-83-318, dated November 23rd, 1993, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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198 1 and SECY-94-087, dated March 29th, 1994, the staff presentec .s recommendations to resolve this Differing r~x $
2
~ . -
3 Professional Opinion.
4 Staff recommended that the NRC, in 5 coordination with the Health and Human Services and FEMA, 6 revise the current federal potassium iodide policy to make 7 potassium iodide available to the States. The 8 Commission's vote on this recommendation was divided 2-2, 9 and under the NRC's internal procedures, a tie vote on a 10 proposal means that it fails. Therefore, the staff's 11 recommendation was not adopted.
12 On September 9 of 1995, the same member of the
, 13 OGC as a private citizen, submitted a petition for
( ;
\
'J 14 rulemaking under 10 CFR 2.208, requesting a rulemaking to 15 implement the recommendation of the President's Commission 16 on the accident at Three Mile Island, and that the U.S.
17 stockpile the drug potassium iodide, for thyroid 18 protection during nuclear accidents.
19 The request was to amend one of 16 planning 20 standards which licensee and offsite emergency plans are 21 required to meet in order to assure that the option of 22 potassium iodide was included in the emergency plans. j l
l 23 At the present time, we have a situation where 1
24 -- well, in November 24th, 1996, the full Federal i
(-) 25 Radiological Preparedness Coordinating Committee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.
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! 199 1 recommended that the federal government, NRC, or through 1 l
L2 FEMA or.wherever, sh'ould fund the purchase of potassium 3 iodide stockpile for any' State that hereafter decides to i .
incorporate its use as a protective measure for the I 4 l
- 5 general public. l
(
6 ,This was essentially the' resolution of that l i .
7 impasse. Five months later now,'after this 4.
8- recommendation, the States and the-public have yet to j 9 learn of the'new policy because the Federal Register j
- i. 10 Notice has not been published. According to FEMA, this is '
g-11 because the NRC and FEMA are " arranging tha administrative I 12 details to support the new policy".
13 Peter Crane, who is the member of the OGC --
l 14 former member I guess -- yes -- has expressed his opinion
- 15 as a private citizen and he disagrees -- well, he wants to ,
16 know why we haven't implemented this -- why this hasn't 17 been implemented. l' r
18 We're going to hear the gory details of this 19 tangle, first of all from the staff. We will then have ;
i 20 comments by representatives of the NEI, the State of !
21 Illinois, and then we'll see where we go from there.
t 22 Our first presentation is from Mr. Mike 1
23 Jamgochian -- is that it? ;
24 MR. JAMGOCHIAN: Very good.
25 CHAIRMAN SEALE: Of Research, and he will try NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS ]
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200 1 to make some semblance of order out of any confusion that e3 2 I may have generated on your part in trying to discuss
! j v 3 this issue. Go right ahead.
4 Mr. JAMGOCHIAN: I very much appreciate your 5 characterizing the presentation as trying to put some 6 order to this background. My name is Mike Jamgochian.
7 I'm from the Office of Research.
8 As a point of background, personal background, 9 I have been the author for the last 20 years, of all of 10 the emergency planning regulations, standards, regulatory 11 guides in the emergency planning area for the Nuclear 12 Regulatory Commission. And if I haven't been the author I 13 have been intimately involved in the development of those Y2 14 documents.
15 In so doing, I invite any possible questions 16 or insights that you folks might desire, as to what went 17 on many, many years ago. I will try to answer those 18 questions as best as I can remember.
19 CHAIRMAN SEALE: I'd suggest, if we want to 20 really go into a lot of those things we may want to do 21 that at another time.
22 MR. JAMGOCHIAN: Nonetheless, I just wanted to 23 tell you.
24 CHAIRMAN SEALE: I appreciate your offer and n
( ,) 25 we may very well take you up on that.
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1
201 1 MR. JAMCOCHIAN: Okay, fine. Some of this is
- 7. 2 going to be repeating basically, what the Chairman said.
But I'd like to emphasize firstly, this is a status
~
3 4 report. This is not Agent, golicy; this is the Office of 5 Research proposed resolution to a petition for rulemaking.
6 Please understand that point.
7 For background, in 1989 a Differing 8 Professional Opinion was submitted to the NRC by a member 9 of the staff, Mr. Peter Crane, requesting a re-evaluation 10 of NRC's policy regarding the use of KI after an accident.
11 The staff attempted to resolve that petition 12 for rulemaking by developing a Commission paper. That 13 paper went up with, basically, questions to the
- 14 Commission. The Commission came back with more questions 15 to those questions. Hopefully, in 1994, the staff went 16 forward answering most of the original questions of the 17 Commission and making a proposal.
18 The attempt to resolve the Differing 19 Professional Opinion was basically by making KI available 20 to the State and Local governments. NRC intended to 21 accomplish this by coordinating with HHS and FEMA. It was 22 also documented in that last paper that that resolution, 23 the stockpiling of KI for use by the State and Local 24 government, was concurred in by Mr. Peter Crane who
(~);
(_ 25 submitted originally, the DPO -- Differing Professional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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202
-1 Opinion 2 Now that's-important, primarily because as we
. 3 go forward with the following results -- following i' ..
4 4 efforts. .The staff proposed resolution failed by a 2 to 2 4
) 5 Commission vote. On September 9, 1995, a Petition for i 6 Rulemaking was submitted to the NRC to require the use of-i
! 7 KI as an emergency planning protective. action. In other 8 words, modifying 10 CFR 50.47 which is one of our planning
- 9 standards used in emergency planning and referenced in 10 10 CFR 50 as well as Appendix A.
11 Again, this Petition for Rulemaking was 12 submitted by Mr. Peter Crane as a private citizen. Now,
- I 13 going back to 1985. In 1985 the original KI policy was j 4
O 14 established by the FRPCC. Now, I'm going to use that 15 acronym several times. That pertains to the Federal ,
[ 16 Radiological Preparedness Coordinating Committee. It is a 17 group of federal agencies chaired by FEMA; NRC is a {
18 member. ;
19 In mid-1996 the FRPCC convened an ad hoc ,
20 subcommittee to re-evaluate once again, the federal KI 21 policy. Now, this is the third time a subcommittee was 22 convened on KI. The first one was 1985, the second one i i 23 was in 1994. And basically the '94 subcommittee agreed !
24 with the. original finding; that KI should be stockpiled
,25 for emergency workers and institutionalized people, not NEAL R. GROSS ,
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_ _ _ . . _ . - - - . , ,, . - . - - .6
203 1 the general public.
~
2 Once this Petition for Rulemaking was
( 'S V submitted, the FRPCC reconvened another subcommittee in 1 3
4 1996. The FRPCC subcommittee, as part of their 5 deliberations, conducted a public meeting in June of last 6 year. In October, the FRPCC subcommittee concluded its 7 report on KI for general use.
8 Please focus on that distinction. In 1985 and 9 since 1985, the subcommittee as well as the federal 10 agencies, agreed that KI should be stockpiled for workers 11 and institutionalized people. The focus now is expanding 12 that to the use by the general public.
-_ 13 I'll go -- in my next slides we'll focus on
\ i
\' 14 what that subcommittee report findings were. In October 15 of 1996 the full FRPCC voted unanimously to concur with 16 the subcommittee's recommendations. All the FRPCC members 17 voted to concur. As I said, unanimously.
18 Additionally, in parallel with all of this, a 19 federal stockpile of medical supplies, including KI, has 20 been established. Right now it's in two states and it's 21 being expanded. And that was certainly a separate entity, 22 but it was focused on terrorist events. It was originally 23 situated at the Olympics and then it was moved to both 24 cities that focused on - that had the national
,i 25 conventions.
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204 1 Now, that stockpile of medical equipment
<3 2 including KI, is currently in two states today and will be
)
'~'
3 expanded, depending on the day -- I was told 11 states, 4 then I was told 21 states, and then I was told 15 states.
5 Nonetheless, just focus on the word, it is being expanded.
6 MEMBER KRESS: How much KI are we talking 7 about in that stockpile?
8 MR. JAMGOCHIAN: I don't know. It is 9 sufficient, I believe -- no, I don't know. Now the third 10 slide, this is the FRPCC subcommittee report. The 11 findings of the subcommittee were: 1) the federal 12 government should fund the purchase of a KI stockpile for 13 States if the States want to include KI as a protective
, 4
'/ 14 measure -- that's a big "if".
15 The second finding: the 1985 KI policy 16 statement should be softened to be more flexible and 17 balanced. Now --
18 MEMBER BARTON: What does that mean?
19 MR. JAMGOCHIAN: Yes, I'm going to say that.
20 Basically, originally, the statement was put in there, KI 21 for the general public should not be required. That's 22 pretty strong bureaucratic language. Instead, it's i l
l 23 recommended now, KI, while not required, may be selected l l
24 as a protective action by the States. So it's certainly I
(~~'s
(_,) 25 not focusing on the negative. l l
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205 1 The last element of the subcommittee report:
,-s 2 that local jurisdictions as well may consider the use of e ,
C/ KI for the general public after consulting with the 3
4 States, if that in fact, is appropriate with the State and 5 Local governments.
6 Now again, try to focus on -- there are 7 several things ongoing at the same time. One, the FRPCC 8 subcommittee was established; two, the terrorist effort 9 was ongoing, as well as evaluation by the staff of a 10 formal Petition for Rulemaking.
11 As part of the last element, the NRC staff's 12 procedure for resolving a Petition for Rulemaking, 13 requires the publication in the Federal Register for
( i A' 14 public comments. As a result of that publication, 63 l 15 public comments were received, and they typically divided 16 as many of the emergency planning documents end up.
17 In support of the petition you had 18 environmental groups, members of the public, you did have 19 the American Thyroid Association, and a videotape that was 20 submitted as an attachment from the environmental groups.
21 Opposition to the petition, again, as one 22 would envision: 20 utilities, nine State governmental 23 agencies -- and it's interesting to note, all of the 24 governmental agencies, State governmental agencies that (O_) 25 responded to the petition, were negative. They did not HEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE., N W.
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206 r ,
l' perceive
- hat this was a good thing to do. .
'2 Two Utility interest companies, one letter 3 signed by 12 health physicists, two State universities, o j 4 and one-member of~the public.
5 Now this slide focuses on the status of'the 3
[ 6 proposed resolution to the petition for rulemaking. We've i
7 received comments and concurrences from all of the NRC ,
l 8. offices except one. It is now being reviewed'by the ACRS.
9 It is to be reviewed by the CRGR. A copy of the proposed 10 research paper for resolving the petition was sent to.the _;
11 CRGR. They have not determined whether or not they wish r ,
f 12 to review it.
13 A final proposed staff resolution is
- - 14 anticipated to go to the EDO after incorporating your {
i-
[ 15 comments and after incorporating the comments received 16 from the different offices, by the end of May; although, l'7 in talking to the EDO this past Thursday, I was told that ,
5
- 18 the Paper would very much be appreciated by the end of 4
19 April. So there is some push to resolve this issue.
20 Based on discussions with FEMA, with the NRC l
21 representatives to FEMA, this slide is presented for your s.
22 information. These are the elements of the proposed FRPCC t 23 Federal KI Policy. It was originally anticipated that ,
24 this was going to be published in the Federal Register in
'25 January of this year, then February -- and I informed FEMA NEAL R. GROSS - ;
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. . - . . ~ _ . - . . - _ - . - _ - - - . - . -- , - . - .- . ..
207 ,
that I had this meeting sometime in' April, and they said,
~
l 1
Lo and' behold .I 2 well surely it.would be published by April.
~
3 it's April ~;.it has not been. published.
4 But the. fundamental elements, it is
(
5 anticipated, will not change. The implementating 6 procedures as to how'these elements are carried out are 7 being negotiated.today. Th'e fundamental elements of the ;
j 8 FRPCC Federal KI Policy, as perceived by the Office of Research, is that stockpiling and distribution of KI for
~
9 l
10 the use by emergency workers, institutionalized people, i i ;
j 11 and the general public, has been approved, e 12 The stockpiling and use of KI for the general 13 public is totally at the discretion of the State and Local ,
s i
( 14 governments, not at the discretion of the federal 15 government. This is not a requirement. This is an offer.
16 And lastly, the federal government will ;
17 provide funding to States for an adequate supply of KI if ;
i 18 the States request it, if the States plan on using it as :
?
19 part of several-protective action strategies in the event 8
20 of an emergency at a nuclear power plant. Again, focusing l 21 on the very last statement on that page, the implementing 22 details are still being negotiated within the FRPCC. s 23 Some of those details involve who should pay, j i
i 24 obviously; what procedures would we look to in the State
( 25 plans prior to paying for this KI. A State just cannot
?
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208 1 say, we'd like a bunch of KI, send us come money. They've
, ~3! 2 got to have plans for stockpiling and for distribution.
%J 3 MEMBER BARTON: Mike, who paid for the supply 4 for the Olympics?
5 MR. JAMGOCHIAN: I believe it was HHS. That's 6 a totally separate terrorist --
7 MEMBER BARTON: Okay. It wasn't federal -- it B wasn't under this program?
9 MR. JAMGOCHIAN: No.
10 MEMBER BARTON: Or had Olympics again in some 11 other State and the State requested KI for terrorists, it 12 would not be covered by this program?
13 MR. JAMGOCHIAN: Totally.
,,3 14 MEMBER BARTON: It's strictly nuclear power 15 plants?
16 MR. JAMGOCHIAN: Totally different.
17 MEMBER KRESS: Do any States --
18 MR. JAMGOCHIAN: Parallel, but totally 19 different.
20 MEMBER BARTON: I've got you.
21 MEMBER KRESS: Do any States presently 22 stockpile KI?
23 MR. JAMGOCHIAN: I thought -- Aby -- let me 24 ask some of the folks in the back. Does Tennessee do it?
t 8
(_,/ 25 MR. MOHSENI: Yes, Tennessee and Alabama.
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209 1 Tennessee and Alabama we understand, have stockpiled KI.
,3 2 Aby Mohseni from Incident Response Division.
(
'~'
3 MEMBER KRESS: Do you know where they keep it?
4 Is it at hospitals or is it in its State capital, is it 5 near the nuclear plants, or in a warehouse somewhere out 6 in the country?
7 Please identify yourself when you get to the 8 microphone.
9 MR. NELSON: Alan Nelson with NEI. Tennessee 10 -- I have a slide on this that I'll present during my 11 presentation. And what they did was, originally they 12 predistributed it in, I believe 1982, but since then they 13 have it at the reception centers for people to pick up if I,. I 14 they so need it.
15 MEMBER KRESS: The State does?
16 MR. NELSON: Yes.
17 MR. JAMGOCHIAN: What reception centers?
18 MEMBER KRESS: Site boundaries.
19 MR. NELSON: At reception centers where people 20 might evacuate to, in order to pick it up at those 21 centers. What they found though was -- it's kind of 22 interesting.
23 They went door-to-door and distributed it, and 24 only about 66 percent of the population accepted the I
'(q,) 25 delivery of the KI to the house. A couple of years ter NEAL R. GROSS COURT REPORTERS AND TriANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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210 1! they said, we will make KI-available to you -- you the 2 public withi'n the ten miles -- but you need to come . pick j 3 it'up at the reception' center.
4 Of the people that lived there, only 32 ;
5 percent went and' redeemed the KI. And then they did --
l l
6 in 1992 they did another campaign on distributing KI to (
7 the public, and at that time only ten percent of the l 8 public has come to retrieve the '*I.
9 So you know, the program as itself, while it !
f i
is established in the State of Tennessee, they are j 10
)
11 reconsidering, you know, its use, because it's not widely [
i 'l 12 distributed or seen necessary by the public to come and, l i
! 13' you know, pick it up.
. 14 CHAIRMAN SEALE: I understand the State of f
1-- !
- 15 Maine has also expressed a desire to --
i 16 MR. JAMGOCHIAN: That's correct. !
t 17 CHAIRMAN SEALE: -- to be covered under this .j 18 program once it's in place. ;
4
.[
3, 19 MR. JAMGOCHIAN: Right. The State of Maine a- .
20 has contacted me and we've had some discussions on this. ,
V t 21 It's interesting to note, on the letters received from the j i
22 State and Local governments, and focusing on the fact that j 23 they all opposed agreeing -- they all opposed the Petition !
24 for Rulemaking -- their focus was not stockpiling of KI. f
, :25 Their focus was, well what do we do with it now? How do
. NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. [
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T 211 1 we implement it?
s 2 It's never been -- or, I'm sorry, shouldn't
/ 't Q ,)
3 say that -- it has not been surfaced, in my mind anyway, 4 that anybody or the State or Local governments are opposed 5 to having this, purchasing it, or having it purchased for 6 them by the federal government. Their concern is -- okay, 7 if we have this --
8 CHAIRMAN SEALE: How do we take care of it?
9 MEMBER BARTON: Distribution.
10 MR. JAMGOCHIAN: Well, do we distribute it --
11 our focus has always been evacuation. Do we start handing 12 out pills while we're evacuating people? No. Do we have 13 it at fire stations and all of a sudden the sirens go off K/ 14 and all the Dads run to the fire stations and have fights 15 -- they're not going to get in line to get some pills.
16 While you're evacuating, if you do have these 17 pills are the people going to say, well, I just took the 18 magic pill; we can go home and watch TV now? Once the 19 States have it, is the federal government going to say, 20 okay, KI is only good in the early hours of an emergency.
21 Now prove to us you can distribute it within these short 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
23 So these are all implementing problems. No 24 one's really against having a bunch of KI in a location.
() 25 It's really focusing on, what in God's name do we do with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
212 ;
1 this stuff'now?
- l l2 The last slide is the recommended conclusion
'3 by the Office of'Research staff. Number one is to deny 4- the Petition for Rulemaking. Now the logic behind that 5 is, a rule change is not required when advising States of i 1
6- the availability of federal funds to purchase KI or.just 7 advising them as to the availability of KI in the event of
}
8 a' terrorist event.
~
That's not necessary for any. kind of :
i 9 rulemaking. j 10 It is also recommended to endorse the final 11 FRPCC full committee, hopefully, 1997 Policy Statement on i
12 the distribution of potassium iodide around nuclear power l 13 sites for use as a thyroid blocking agent. Again, this O, 14 should be published this year.
15 Any questions?
16 MEMBER KRESS: Yes. It seems like that policy l P
17 is to say, we'll make it available out'there, States, if ,
18 you want it. Let us know and we'll -- and give us a plan 19 for what you want to do in terms of distributing or f 20 stockpiling, and we'll pay for it. ;
21 MR. JAMGOCHIAN: That's it. <
22 MEMBER KRESS: Is that basically it?
4 l 23 MEMBER BARTON: Does it even require a plan,
- 24'- or is it just, the State just says, I want it, or is it --
) --
25 MR. JAMGOCHIAN: Oh, no, no. They're going to NEAL R. GROS 5 COURT REPORTERS AND TRANSCRIBERS 4" 1323 RHODE ISLAND AVE.. N W.
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w -
yw -v -~~w y
213 1 have to show --
2 MEMBER BARTON: They will have to provide a fen N.N 3 plan?
4 MR. JAMGOCHIAN: Yes.
5 MEMBER BARTON: On how they're going to 6 distribute it or what they're going to do with it?
7 MR. JAMGOCHIAN: What they're going to do with 8 it, yes sir.
9 MEMBER BARTON: Okay.
10 MEMBER KRESS: So the practical result, it 11 seems to me, of a policy like that, is some States will be 12 enlightened and ask for it, some won't; some will have 13 reasons they don't want it. And you'll get extremely 14 uneven protection, if you want to call it that, with a 15 policy like that.
16 Is that what you want as a result of this 17 policy? You want it to end up with uneven protection, 18 willy-nilly at the whim of a bureaucrat that maybe is not 19 well-informed at Local governments or State governments?
20 Isn't that the likely outcome of such a policy?
21 MR. JAMGOCHIAN: Well, understand, from the 22 very beginning in developing emergency plans or detailed 23 emergency planning requirements after TMI, the focus has i
24 always been on evacuation. )
,m b) 25 MEMBER KRESS: Sure.
1 NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE., N W. ,
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214 1 MR. JAMGOCHIAN: 'Okay. I really wouldn't
'2 characterize the making available of an additional 3 protective measure as willy-nilly. I really wouldn't 4 characterize it as uneven protection. The State and Local 5 governments,_ their job is to protect the: health and safety.
6 of their folks.
7' For us to make it available to them if they 8 want'to use it in their protective strategies, I think is 9 very appropriate. I think it would be very difficult for
- 10. the federal government'to say, you will use this, you will 11 have this.
12 MEMBER KRESS: That's not the thrust of my 13 comment. The thrust of my comment is, it is probably O 14 reasonable to expect the federal government could 15 stockpile this stuff and make it available to the States 16 if and when needed. It's a different concept.
17 MR. JAMGOCHIAN: But see, again --
18 MEMBER KRESS: That's not requiring them, now.
19 MR. JAMGOCHIAN: Oh, no, no.
20 MEMBER BARTON: But that's a bigger 21 distribution problem isn't it, than if the States haveuit 22 and stockpile it?
^
23 MEMBER KRESS: Oh, of course it is. Of course Y .24- it.is. .It comes down to the question of, what is 25 appropriate for a federal government responsibility as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433 0.
_ _ ._. __ _4 . . - . - _ _ . _ _ _ .
, ~215 .
t l
1 opposed to State government? ,
[
2 MR.'JAMGOCHIAN: But'see some of --- j O 3 . MEMBER'KRESS: And that's~a tough question to 4 answer.
5 MR. JAMGOCHIAN: But some.of that is. going to i e
6 be done as part of that' terrorist activity.
I 7 MEMBER KRESS: Yes, but why dilute the message l 8 with something like that? Why not just say, the federal 9 government thinks this is a good idea as a precautionary;
)
10 defense-in-depth measure. We will make it available, 11 we'll stockpile the stuff you States; it's available here r
12 if you want it and when needed, and we'll make it
.. 13 available. And we'll figure out how to distribute it.at ,
~
14 the time. 'l 15 MR. JAMGOCHIAN: Well, see again, that's the !
i.
16 big problem. We'll figure out how to distribute it. :
1 17 MEMBER KRESS: Well, it's like a Field of i
18 Dreams. If you build it they will come.
19 MR. JAMGOCHIAN: Well, let's take a look at --
l 20 that was one reason we put in this slide, and at one point i 21 it was thought by members of the staff, putting in this i
22- terrorist effort would confuse the issue. l t
23 MEMBER KRESS: Yes, that's what -- I think it i
- 24. does. l M: $
- 25. MR. JAMGOCHIAN: Yes, what are doing with G- !
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1323 RHODE ISLAND AVE., N.W. - -!
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216 1 that? -Why'is that there?
1 2 MEMBER KRESS: I think it's a separate 1. issue. \
- O 3 MR. JAMGOCHIAN: But-if the States knew that 1
4 there was a stockpile of KI in 21 States or whatever
- 5- number it is, and it could be used -- there was some- ;
6 thoughts that it should be at VA Hospitals, that -- ,
7 MEMBER KRESS: I think that would be a I
8 reasonable policy, there.
I 9 MR. JAMGOCHIAN: Well, that is being pursued. ;
t
{
10 The' Charter and the money is under a terrorist event kind 11 of thing, but it will be known to the States that that is {
i !
12 available. So that is being pursued. ;
13 Now, in conjunction with simply saying, okay, j I
14 NRC down in our basement has this much KI and it's 15 available to you, States, now you get into what I focused i
16 on earlier: implementing that, distribution. :
17 MEMBER KRESS: You have the same problem with 18 the terrorist stockpile. It's the same issue. -
19 MR. JAMGOCHIAN: Well, not really because .
I 20 there you have it within 20 States or whatever number. ,
21 MEMBER KRESS: Well, that's what I'm saying to l
- 22 do. Put it in regional areas, like 20 States. But it ;
23 sounds like you're planning on doing that with different -
24 -
l 25' MR. JAMGOCHIAN: Under a different guise.
NEAL R. GROSS l
- COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE., N.W. a (202) 234 4433 WASHINGTON. O C. 20005-3701 (202) 234-4433 J
- ~ , . ,
- 217 1 Exactly, exactly. And under a different' budget -- but it .
2 is going to be out there. So it's not like the' federal, ;
l.
3 government is negligent,-is not doing something. ;
4 MEMBER KRESS: Yes, but --
5 MR. JAMGOCHIAN: Clearly,-we're.much better l
6 off than TMI -- .
7 MEMBER KRESS: Sounds to me like.it's hiding 8 it just to not smear the nuclear power industry's image -- ,
9 MR. JAMGOCHIAN: Oh, no. No sir. This was in i
10 addition to. Clearly, if a State says we want this and we )
~1 want to keep it at the capital, and we will then lay out 12 these procedures.on what to do with it, you can have it in r
13 40 States, 50 States, okay?
14 MEMBER KRESS: I think the federal government l
15 ought to say, it is here, and if you want it we'll work ;
16 with you on distributing it. Different viewpoint. ,
17 MR. JAMGOCHIAN: Yes.
b 18 MEMBER KRESS: And I think they ought to say, 19 this is here in the case it's needed as a defense-in-depth a 20 concept for nuclear power, and not -- I don't think you 21 should say this is for terrorist activities. You could 22 say it's for that also. You know, we're obfuscating the
- 23. issue when we.do it the other way.
t
! 24 MR. JAMGOCHIAN: Well, again, I think it's --
l
> 25- you're not trying to hide something. I think it's an NEAL R. GROSS -
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218 1 added-to.
,r") 2 MEMBER KRESS: Well, you may not t' trying to s !
u-3 hide it but it looks like it's being hidden when you do it 4 .t way.
5 CHAIRMAN SEALE: Well, I think you get the 6 point on that. I'd like to bring up a couple of other 7 questions, give other people an opportunity to ask 8 questions. Actually --
9 MEMBER SHACK: Just let me clarify one point.
10 I mean, that phrase, "as well as terrorist events", means 11 nothing, right? That could be left off of here?
12 MR. JAMGOCHIAN: That's correct.
,_ 13 CHAIRMAN SEALE: Earlier you characterized a i ~j 14 statement in the previous position with respect to KI as 15 being bureaucratic language, bureaucratic advice, to the j 16 effect that the general public -- it's not recommended for I
17 the general public.
18 When I heard that phrase my impression was, 19 that might be very good medical advice, and while my 20 medical -- or my treatment at the hands of the medical 21 community now does seem kind of bureaucratic upon 22 occasion, that's not what I look for in medical advice.
23 I have real questions about the possibilities 24 of side effects, allergic reactions, that sort of thing.
+,,
i
(_/ 25 And I understand -- or I have been told -- that that is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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219 1 real concern. !
2 MEMBER BARTON: It is.
7S
( )
3 CHAIRMAN SEALE: And yet that seems to be --
l 4 well, no word has been said about it so far.
5 MEMBER KRESS: Well, it's approved by the FDA 6 for this use.
7 MEMBER BARTON: Yes, but there's people that 8 are allergic to it -- there are people that would have a 9 bad reaction to taking it and may not even know that ;
I I
10 they've got a bad reaction to taking potassium iodide. !
11 Right now it may be approved as a drug by the FDA, but 12 that doesn't mean everybody can take it without having 13 severe, you know, side effects. l l
i \
l -
\) 14 MEMBER KRESS: It seems to me that those l
l 15 arguments have already been debated, and it says it's good 16 for workers, it's good for use on civilized people --
17 MEMBER BARTON: Because they can't go anywhere 18 --
19 MEMBER KRESS: -- and it's put to them why 20 isn't the same problem --
21 CHAIRMAN SEALE: Hey, penicillin is approved 22 by the FDA, and you're not going to put any of that in me.
23 MEMBER KRESS: I understand.
24 CHAIRMAN SEALE: And I just wonder, what about
(,) 25 that particular question? Is there some sort of warning NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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220 process or what? ;
1 l
- 2 MR. JAMGOCHIAN: Okay. The FDA is a member of '
l
(
LJ 3 the FRPCC.
4 CHAIRMAN SEALE: Fine.
5 MR. JAMGOCHIAN: Now, the FDA, in voting -- in 6 doing their vote on the FRPCC to fund this, weighed the 7 value and the impact. Now clearly, as you said, you're 8 allergic to penicillin; so am I . Penicillin is still out 9 there.
10 CHAIRMAN SEALE: Yes, but there's a very 11 active program to make sure that my particular 12 circumstance, vis-a-vis penicillin, is up-front and 13 clearly ivailable before the decision is -- or, when the
! )
'~/ 14 decision about what kind of antibiotics to be used -- that 15 would be used, is made.
16 MR. JAMGOCHIAN: Right, right.
17 CHAIRMAN SEALE: Is there any kind of, pre-18 screen. .i I guess you might say?
19 MR. JAMGOCHIAN: Okay. Pre-screening of the 20 individuals within the general public around nuclear power 21 plants, no, I don't believe so. I don't think that would 22 be practical. But I think clearly, when these pills are 23 distributed, if necessary, there would be certain warnings 24 on the package.
(
() 25 I've got a package here -- and this is an old NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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f 221 1 one -- and it has warnings on it. This is what it looks 7s 2 like. Again, this is quite a while ago.
( l U/ It is perceived, again, that when the FDA 3
4 voted on the FRPCC to make this available to the public, 5 for public use, that the value, as well as potential 6 allergic reactions, clearly, the staff -- in conjunction 7 with HHS -- has recognized the concern of potential 8 allergic reactions to this medication.
9 But they also focused on the potential 10 benefits. And clearly, it's considered, the potential 11 benefits are significantly outweighed the negatives.
12 VICE CRAIRMAN POWERS: Did they do a --
13 MR. JAMGOCHIAN: Again, I think when they give n
- t. )
N' 14 these out that they would have warnings on them as 15 appropriate.
16 VICE CHAIRMAN POWERS: Did they do anything 17 quantitative on looking at the risk benefit potential on 18 this particular material?
19 MR. JAMGOCHIAN: The FDA? That, I really 20 don't know.
21 VICE CHAIRMAN POWERS: How about the staff?
22 MR. JAMGOCHIAN: The staff did significant 23 studies on the risk benefit, not -- I don't believe 24 focusing on the medical adverse reactions. It was taken (q,) 25 into account, basically the data that was given to us by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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222 1 i
i 1 the FDA. I think the FDA did all of that concern as to ,
73 2 potential side effects.
l 1 LJ You have to realize that an 3 MEMBER KRESS:
4 allergic reaction to penicillin can be pretty lethal, with 5 small amounts of penicillin, and that your probabilities 6 of getting a penicillin shot at some time in your life 7 without the screening process you talked about ahead of 8 time, are pretty doggone good.
9 CHAIRMAN SEALE: Yes.
10 MEMBER KRESS: And allergic reactions to 11 potassium iodide are not nearly that severe, and not 12 nearly the large number of people are -- have a reaction
,_ 13 to it, and your chances of having to take one are pretty
?
\- 14 slim -- taking a pill -- in the first place. So I don't 15 think it's comparable to talking about an allergic 16 reaction to penicillin as a similar problem --
17 VICE CHAIRMAN POWERS: But a risk analysis 18 that reflected all these points would make it clear.
19 MEMBER KRESS: Would make it clear if you had 20 a good risk analysis.
21 CHAIRMAN SEALE: I can think of, you know, if 22 I want to be very creative here, I could think that one of 23 the most intriguing terrorist attacks I could have would 24 be to con everybody into taking KI. And just take your
,r~,
\) 25 chances.
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223 1 VICE CHAIRMAN POWERS: I can't resist pointing r m. 2 out that one of the most hazardous scenarios that we L 3 envisioned for stealing plutonium was to steal some and 4 then claim that you had distributed it over a city.
5 MEMBER KRESS: Watch the panic?
6 VICE CHAIRMAN POWERS: Yes. It was as bad as 7 actually doing it -- actually it was worse than actually 8 doing it because the authorities could not -- would be 9 cast in the role of having proved that you didn't, and 10 they can't do that. Whereas, if you did do it they could 11 actually identify where it was and where it was not.
12 CHAIRMAN SEALE: Well, I think you understand
,_. 13 some of our concerns here.
[ h 14 MR. JAMGOCHIAN: Clearly.
15 CHAIRMAN SEALE: Are there any other questions 16 or observations? I hope you'll stick around because we've 17 got other people that are going to be making some 18 comments, and I think it would be very worthwhile to have 19 an opportunity at the end to perhaps, share questions 20 among the other people that are left.
21 MR. JAMGOCHIAN: Certainly.
22 CHAIRMAN SEALE: Okay, if you're through?
23 MR. JAMGOCHIAN: Yes sir.
24 CHAIRMAN SEALE: Okay, then we'll have Mr.
/^s
'x ,) 25 Nelson from NEI.
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224 l l
1 MR. JAMGOCHIAN: Thank you very much.
3 2 CHAIRMAN SEALE: Thank you, very much.
'~'
3 MR. NELSON: Good morning. My name is Alan 4 Nelson. I'm the industry representative from Nuclear 5 Energy Institute. We've been following this issue for 6 years and years. In fact, I've been involved with this as 7 a Utility employee and as on the staff of NEI.
8 I'm going to track a similar discussion that 9 Mr. Jamgochian gave this morning, but I'll attempt to 10 answer a lot of questions that you had in distribution and 11 the reason that we don't think potassium iodide is needed 12 for the protection of the health and safety of the public.
13 Primarily, the industry's focus as it's been ,
1 i i' over the years, is evacuation. And at the onset of the
~
14 l
15 emergency planning process, over the past years -- even 16 before the introduction of the KI policy as it stood --
17 takes us back almost to 1978.
18 And since then some of the data that 19 established that -- the WASH 1400 source term data and 20 other data that has been updated, which can also increase 21 out awareness of why KI may not be needed for the public 22 as it stands.
23 The industry in itself has matured -- our 24 alert notification -- we notify the public within 15 25 minutes of awareness, make protective action NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1%D RHODE ISMND A\E , N W.
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225 1 recommendations, emergency response data system is 7s 2 available providing technical data to States, NRC alike.
( )
~
3 The SPDS-type systems are available in the 4 control room; they're aware of plant conditions, can uake 5 protective actions and emergency action levels, being 6 proactive and in advance of a lot of emergencies 7 occurring.
8 Given that and the notification and the 9 application of the emergency plans that are in place 10 today, where they've had thousands of exercises and 11 actually have worked these on real events, have in 12 themselves, proven that emergency plans are effective and 13 do work in the real world.
(~~\
! l As was stated earlier, there are three
\/ 14 15 particular federal agencies; all three of these did sit on 16 the FRPCC committee and they all had distinctive roica.
17 The NRC overall, FEMA of course, has the offsite, and the 18 EPA establishes the protective action guides.
19 EPA does recognize though, as well as FDA, l I
20 that KI can be effective, okay, but they also note that l
21 the protective action of choice would be evacuation.
22 I'm not going to repeat the current policy, i i
1 l
23 The current policy recognizes that KI should not be 24 required, and if the State and Locals -- if they so choose r~3
! ) 25 -- can go ahead and utilize it as they wish. In the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l
226 j i
1: package that I've given you as a handout, and-I believe in .,
l the -- it was discussed earlier, are'the plans, and is l
,- 2 3 there guidance available to the States and Locals and the j 4 Utilities in use of. protective action for the public? l 5 I've provided in the --'behind the first blue !
2 page -- a listing of the regulatory framework thattis in
~
- 6 {
i
- 7' place today. On page 2 of that, I want to bring.your i 8 attention to the REP-14 manual, which does'in itself, in I
- 9 objective 14, state that " Implementation of protective ;
i
- 10 actions -- use of KI for emergency workers, institutional
! 11 individuals, and the general public". :
I '
i 12 Then you would look at those criteria 1, 2, 3, i
13 and 4 which set in place the process in which a State or .
Local emergency organization would develop plans in which 14 ;
~
15 to satisfy that. In today's -- other than Tennessee, most {
16 of the States when you get to that segment of the plan- l 17 they put in, its not applicable because they have chosen I
18 not to distribute it to the public.
19 So what I'm saying is, the guidance and the ;
20 scope is in place. This is part of the FEMA document, I 21 they train on this, and they provide that advice and 22 technical assistance to the States and the locals if so l 23- desired.
1 1
24 So let's just say that a State now comes 4
) 25 forward and wants to develop a plan and so-call -- take i
t: NEAL R. GROSS :'
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. . .__._ _. -- ~. _ . _ .
227 -
1 advantage of the purchasing process-that-the FEMA and NRC l They would have~to develop.these- f
~
2 may afford to put out.
u') 3 plans, they would have to be approved by their State ;
I 4 agencies, they would have to be forwarded'to FEMA for i
5 their review and approval, j 6 And then at tha time when they develop a '
r 7 Ecenario-or an exercise in itself, they may have to 8 demonstrate, or at least simulate, the process of use of -
I 9 - not use of KI, but just -- well, see, this is just like i 10 -- KI falls into the same kind of, do we demonstrate 11 evacuation during an exercise? And the answer is.no.
12 There are a lot of complications with 13 distributing KI in itself, and if-you bear with me I'll b 14 get into that level of detail, because that was brought up .
15 during the FRPCC meeting which I participated in, as well )
16 as others.
i In the back part of the package that I :
17 18 provided to you, NEI submitted a white paper originally '
19 based on the second document and the difference of (
20 opinion, and in that we looked over the federal policy ;
i 21 considerations, background, historical events -- much of 22 which Mr. Jamgochian has provided us. ;
23 What triggered many of the, what we're seeing j People felt that KI was to be i 24' today, is really Chernobyl.
I 25 distributed there, many of the European folks have )
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{
_ , - ~ _ _ ,_ _ ._ ' l
228 1
1 distributed KI. The studies have shown, with those l
,r S 2 applications in the United States being one and the same,
\ )
Q ,/
3 can we say the Chernobyl event would occur in the United 4 States? No. We have better protection, we have different 5 emergency plans, and so forth. Our paper explores that.
6 Source term studies are different from the 7 original KI than what we're looking at now. EPA 8 protection action guides, as I noted, recommend '
9 evacuation. And again, the industry experience which I 10 discussed a few minutes before, but we'll come back and 11 discuss a little further, is the TVA experience and the 12 problems that they had.
13 The industry, given all thic, our papers i )
\/ 14 clearly, strongly urge the NRC to retain its policy and 15 that they did with the 2-2 vote.
16 On the KI distribution in Europe, we have 17 taken a look at it, the NRC has taken e. look at the 18 studies, at the European philosophy. First of all, their 19 emergency planning zones are not as large as ours, they 20 don't drill as often as we do. Our organizations involve 21 the federal government, the state, the Local, the Utility 22 all working together. These are tested annually, and 23 often during drills.
24 We have done -- actually there are thousands q
(
i
(_) 25 of exercises done, plus response to real events. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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229 1 European community does not have the 15-minute 2 notification -- the alert, the sirens, the alert-and-73
)
3 notification process that we have -- in addition to the 4 facilities that we have in the United States: the 5 emergency response center, the NRC support of an 6 emergency, the TSC, and so forth.
7 It'was interesting in the review of the 8 Chernobyl event that the KI around the site itself was 9 given after the event occurred, and if you read the 10 studies, a couple of things actually happened. It was 11 moreso to prevent the iodine uptake from the foodstuffs.
12 Now, what they found was, in that particular 13 area, food was grown locally. In the United States y~3 L'-) 14 they've shown that the food around these facilities does 15 not usually come from the local facility around the plant; 16 you know, it's transported like from Florida or California 17 or many different areas. So food can be taken in this 18 country, in a number of different directions.
19 I just want to just discus' the French 20 situation because they are either in the process or 21 already have distributed KI to people that live around 22 their facilities. Interestingly enough, the French came 23 in to talk to us and they spent a number of weeks here in 24 the United States.
,f 3
(_) 25 I know they came and talked to both the NRC NEAL R. GROSS COURT GEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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I A 230
-1 and FEMA -- t'is h was'last fall -- and they visited Hatch, 2 Saint Lucie, I think also the Surry plant,.to see how they -
O 3 had developed their emergency plans.
i When they came to see us -- now, this is the_
~
4 5 NRC contingency of theIFrench government -- when they_came 6 in to see us they explained that their plans were not as
'7- sophisticated as ours. Their_ alert notification, their j 8- event' classification scheme itself, the international .
9 scale, does-not recognize _the details of the protective 10 actions that we apply here.
11 They said that the distribution of KI'in f i
12, theirs was more of a political maneuver because of the ,
13 uneasiness of the folks living around these plants, to 14 have confidence in the government to support emergency l
15 preparedness programs. So I thought that was an 16 , interesting insight from the, you know, the French itself.
17 The industry experience is what I spoke a 18 little bit about before, but I don't want to repeat the 19 whole thing in its total. They gave out 66 percent door- ,
20 to-door, but they found that it wasn't very cost-effective i
21 back in81 at $125,000. In '84 they said, if you really i
22 want it -- because it expired -- at that time I think they l.
23 had a 3-year shelf life -- I think it's been expanded to 24 five now. ;
, () 25 So what they said is, if you want it, you come NEAL R.4RO55 :
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231 1 to the reception center, and they put in a mailer in each 73 2 person's mailbox and said, well okay, if you want it, only
\
) 3 32 percent of the folks came and picked it up.
4 MEMBER KRESS: What is it that limits the l 5 shelf-life of KI? Does it absorb moisture and get 6 dissolved in it and then evaporate away?
7 VICE CHAIRMAN POWERS: It is actually a 8 decomposition reaction caused by defects that lead to 9 formation of I. inclusions in the material.
3 It is sort of 10 a decomposing --
11 MEMBER KRESS: This decomposition is driven by 12 what?
13 VICE CHAIRMAN POWERS: It is --
/3
'- 14 MEMBER KRESS: An oxidation reaction?
15 VICE CHAIRMAN POWERS: It is probably cosmic 16 rays, believe it or not --
17 MEMBER KRESS: Cosmic rays --
18 VICE CHAIRMAN POWERS: -- it's defects that 19 are forming in the material thermally.
20 MEMBER KRESS: It's hard for me to believe 21 that you can't extend the shelf-life of potassium iodide.
22 VICE CHAIRMAN POWERS: Cool it.
23 MEMBER KRESS: Cool it or coat it.
24 MR. NELSON: Actually, they did extend it from en
( \
25 three to five years, I think, after a series of tests.
( ,/
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232 l l
l 1 MR. JAMGOCHIAN: I'd like to mention something 2 on that. In my evaluation and development of the staff (7 w)
~
3 position, I have looked into and have discussed thAs with 4 two manufacturers, and that shelf-life in fact, has 5 significantly increased, and both manufacturers have given 6 me the same data point; that right now it's a minimum of 7 seven years.
8 MEMBER BARTON: Seven?
9 MR. JAMGOCHIAN: Right, and they said, that's 10 very, very conservative. They said it would probably be 11 indefinite. Now, I think that's very liberal. My 12 perception is, it's between seven and ten years. But they 13 said at a minimum, it is now seven years.
)
14 MEMBER KRESS: Thank you very much.
15 MR. NELSON: I think what was kind of 16 interesting in the end here, they did it again in '92, but 17 then at that point only 10 percent of the public came 18 back. Because they had like their, you know, exchange out 19 the KI that they did have in place.
20 But what turns out to be the humor in the 21 story is, all the thousands of out-of-date vials could not 22 be disposed of in normal trash. So they needed, it turned 23 out, a semi-hazardous-type material in bulk, in itself.
24 So it cost the Utility again, to dispose of
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233 1 it for the fish. So it does cause, you know, other
~
( ~N, 2 complications in itself, just to get it and retrieve it.
() 3 MEMBER KRESS: Would you characterize that 4 history as being a characterization of the strategy of 5 pre-distribution to individuals?
6 MR. NELSON: Absolutely. Well, the fact that 7 they didn't come back and -- yes.
8 MEMBER KRESS: This just says that kind of 9 strategy is probably not very good.
10 MR. NELSON: Right.
11 MEMBER KRESS: And of course, the shelf-life -
12 -
13 MR. NELSON: Causes additional problems.
/_s\
()'~
14 MEMBER KRESS: It talks to that last bullet.
15 MR. NELSON: Sure. It causes additional 16 problems. Given what we know, given the fact that the 17 plants are more prepared today than they've ever been 18 before, the plans have been used for real events; that 19 both the industry and the NRC support evacuation as well 20 as FEMA and the EPA as the primary method of protection.
21 We found that with the sophistication of our programs 22 little is added really, by KI; in fact, it adds 23 complications.
24 And that during the testing on the use of
,/
! 1
(_) 25 these plano, neither FEMA nor the NRC have ever found any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE,, N W.
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234 1 of these plans not implementable. They have found that 7--s. 2 the findings of reasonable assurance and their oversight
( '
3 over the last 15, 20 years of implementation.
4 MEMBER KRESS: What do you mean by adequately 5 protecting the health and safety of the public, in that 6 first bullet?
7 MR. NELSON: The very first bullet?
8 MEMBER KRESS: Yes.
9 MR. NELSON: That the programs that are in 10 place provide sufficient plans and procedures to protect 11 the health and safety of the public. What I mean by that 12 is, that the sophistication of the plans to identify an 13 event at a plant, notify the federal agencies that an
/ ;,
e
'> 14 event has occurred, the recognition of the event --
15 whether it be an unusual event, alert, site or general 16 emergency.
l'1 Now remember, when we're looking at evacuation 18 or protective action of the public, we're looking at 1 rem 19 generally. It's a general emergency; organizations have 20 been put in place; control is alerted, TSC is alerted, the 21 NRC has been alerted, the State and Locals are alerted; 22 the emergency response data system is put on go; data is 23 going to the States -- if they so desire through a 24 memorandum of understanding, which most of them have --
/ ~ ' N.
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235 1 emergency through plant conditions.
2 With that, and the emergency action levels, 73 N
3 they can take action to put the State and Local folks and 4 make recommendations for them to take protective action in 5 a timely, effectivo manner.
6 Now, these plans as they've been developed, 7 have been used for real events: the Nanticoke fire, the 8 PPNL event. Down at Waterford they've had a number of 9 events where they've used the Utility emergency plan. The 10 airport disasters they had in Pittsburgh about a couple of 11 years ago, they used a Beaver Valley plan to go out and 12 help the people that were in that crash in the local 13 vicinity.
\>-
14 So what I'm saying is, these programs have 15 been developed, been tested, analyzad, revisited, lessons 16 learned, improved, over a period of more than 17 years in 17 themselves.
18 CHAIRMAN SEALE: Dr. Kress gave you a loaded 19 question.
20 MR. NELSON: Did I give a loaded answer?
21 CHAIRMAN SEALE: Well, the load is that we've 22 been debating with some of the staff, the real meaning of 23 the phrase, " adequate protection".
24 MR. NELSON: Okay.
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236 1 in a little bit different way. By adequate protection
,s 2 here, do you mean that using these plans that are in place r )
'~
3 and so forth, your expectation is that none of the public 4 would receive a dose in excess of the allowed exposure 5 levels for emergency conditions, to the general public?
6 MR. NELSON: Yes.
7 CHAIRMAN SEALE: So adequate protection means 8 compliance with the rules and regulations?
9 MR. NELSON: Yes, I would feel comfortable in 10 saying that, although -- you know, when you get into the 11 scientific arena, how do you define 100 percent, or 100 12 percent guarantee? You're going to get a certain element 13 of the population that says I'm not going to leave, right?
( l N/ 14 CHAIRMAN SEALE: Yes.
15 MR. NELSON: But let's say that everybody was 16 willing to move on, given the appropriate notification 17 that an event had occurred. The event declarations are so 18 conservative today that we're identifying precursors often 19 before the actual evenu does occur. And the built-in 20 safety precursors allow for protective actions to be taken 21 long in advance of that in itself.
22 You know, it's interesting. We did a study --
23 it's very interesting in an emergency planning phenomena.
24 We did a stud .-nuclear emergencies of 1,000 people i-(\,) 25 or more back in 1990/91 -- I can make it available if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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237 i
1 you'd like. But what we tried to do was look at those
's 2 events that were non-nuclear but were from hurricanes,
! i
%)
3 technological events.
4 You know what we found? We found that people 5 are evacuated in this country at least once a week of 6 1,000 people or more, often without any plans or 7 procedures. And nobody dies on the road, or it rarely 8 happens. People are notified in a, you know, civilized 9 manner without a sense of panic, and are taken to safety 10 at-large.
11 So these plans, while they've been in place 12 and tested, I feel offer a great deal more security than 13 .
many of the non-radiological plans that are out there
(
)
14 today. I hope I answered that.
15 MEMBER KRESS: That's reasonable.
16 MR, NELSON: Mike mentioned the comment 17 letters. I'd just like to reiterate what some of the 18 States said, and I think this, Dr. Kress, will elaborate 19 on some of the concerns that you had.
20 What they were saying that is, we primarily 21 feel that you ought to be evacuating -- as a primary cost 22 of evacuation if they were in time -- distributing those 23 they may have to have -- would they have to have policemen 24 instead of directing traffic, handing out KI as people
,a
( ,/ 25 came by? Should they be going door-to-door?
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238 1 What personnel would they use to use that when 2 they really needed those folks to do other things? Should f 's v
3 the ambulance folks be giving out KI to the general 4 population when they need to be ready to do different 5 things?
6 Again, this is the States' comments, this is 7 not the industry comments. They were concerned about the 8 allergic reactions. And then they were talking about the 9 burdens. And also, they focused on the mix of isotopes 10 other than iodine. Let's not forget that KI only blocks 11 the radio-iodine while we have the rest of the isotope 12 spectrum that would affect the body in itself, so I think 7s 13 that's probably an important point.
! i 14 In the implementation concern that the States 15 have, going back to the TVA kind of case study, they were 16 concerned about where would people keep it, would they 17 have it available when they needed it, and what 18 percentages then, would have demonstrated if there were an 19 actual event? And that gets back to, what would the 20 government require as far as demonstration?
21 Now, I know in the case of TVA, when they come 22 to this portion of the part of the program, I think they 23 usually simulate the proccas -- like we have simulated the 24 evacuation.
(p _,/ 25 Where this becomes difficult is when you get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE (SLAND AVE., N W.
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-. ~ . . . - - - . - . . . - . . - - , - - . . - , . . - . - - - - ,
239 1 into the. children distribution of KI, in order to, at the 2 school level you need-to have. signature by the parent.that O 3 you can give it. Do you'need a nurse that would co-sign 1
f l
1 4 it? Do you need a nurse that would actually. distribute it 5 to the children.'as they get on the bus:to go? j 6 Now, just looking at how. school children -- :
7 many of the plans today for school children, they usually
?
evacuate, in many cases -- I'm not.saying in all -- but in
- 8 i
i
.9 .many cases they evacuate at a site emergency. So they 10 have a go-home program prior to even a general. emergency. ':
t i
~11 So in some of those situations they would have been 12 evacuated even before the total population recommendation i 13 would be made at the general emergency level.
O- 14 So therefore, it causes a number of confusing, j you know, policies and decisions that need to be made at I
'15 16 the State level and at the school level, and the signature ;
17- of nurses and doctors, and would they actually -- would-t l 18 then need -- would a screening criteria be required and !
i 19 who would pay for that screening criteria. For what
- . 20 protective action, I'm not sure it's really that.
21' Even though the federal government may be 22 reconsidering its policy, what the State said was, even if j l
i 23 they do that, they would still not feel that the KI was, !
24 you know, required for them. l 25 The industry in itself felt that it didn't add l t
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240 1 any additional protective action. We supported the NRC s 2 May 6th vote, and we also support the issuance of
\ ]
3 supplement 3 -- which I understand will be final maybe, by 4 the end of this year -- which recommends, emphasizes the 5 use of evacuation as a primary and preferred protective 6 action during a severe accident.
7 And I think that most of the industry-at-large 8 has adopted that philosophy, that they would go to 9 immediate evacuation of two miles and five miles downwind 10 - as a first step in a general emergency severe accident.
11 The industry also supports the FRPCC 12 subcommittee findings that the current policy not be 13 changed. Interesting note that of the survey that they
/~T k- 14 took -- the FRPCC took -- 33 of the 43 States responding 15 were States that said they were opposed to stockpiling.
16 That kind of quantified which States --
i 17 interesting enough, of the ten States that were for KI, 18 okay, five of them didn't even have nuclear power plants 19 in the State. So I mean, that had some -- little 20 relevance.
21 The others were, say Tennessee, Alabama, and I 22 believe two others that were considering the stockpiling 23 of KI. So that's where these states were coming -- on 24 October 3rd which Mr. Jamgochian mentioned, we also
( ,) 25 support the philosophy of the underpinnings of the FRPCC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 2344433 WASHINGTON. D C. 20005-3701 (202) 234-4433
241 1 decision that's under review now by the Commission.
s 2 That pretty much concludes the industry's i )
3 point of view on the KI. We recommend that, you know, the 4 NRC recognize the State and Local's right to provide for 5 public health and safety, and we recommend that the NRC 6 reaffirm their position on the distribution -- not to 7 require stockpiling or distribution to the public.
8 I appreciate this opportunity and the 9 dialogue. Any additional questions that I can --
10 CHAIRMAN SEALE: Any questions? We certainly 11 appreciate your --
12 MEMBER KRESS: Yes.
13 CHAIRMAN SEALE: -- very detailed and helpful s i
'"/ 14 presentation. It's been very useful to us.
15 MR. NELSON: Thank you.
16 CHAIRMAN SEALE: I hope you can stick around.
17 MEMBER KRESS: Yes, I would like to ask him a 18 couple of questions.
19 CHAIRMAN SEALE: Sure.
20 MEMBER KRESS: Do you think it would be useful 21 in the event that we had an accident, to have KI 22 available? Simple question. Would it be useful to have 23 it?
24 MR. NELSON: Well, not with the present plans n
() 25 and procedures that we have, because it may cause more NEAL R. GROSS COOHT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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242 1 confusion of having it available -- the process of ex 2 distributing it, the availability of it --
3 MEMBER KRESS: The answer is no because 4 there's real distribution issues and problems?
5 MR. NELSON: Well, also the plants in place, I 6 think, offer sufficient timing and allowable to evacuate, 7 to take protective actions, which we've seen demonstrated.
8 MEMBER KRESS: So it would be -- the answer 9 is, it would be of little use --
10 MR. NELSON: Right, correct.
11 MEMBER KRESS: -- and that probably the 12 distribution may interfere with --
13 MR. NELSON: In the case of --
?
('-)#l 14 MEMBER KRESS: -- the process we already have?
15 MR. NELSON: Right.
16 MEMBER KRESS: Okay.
17 CHAIRMAN SEALE: Any further questions? Well, 18 I think we should move along then --
19 MR. JAMGOCHIAN: Could I say a few things?
20 I'd like to address a few of the points that Alan made.
21 Going to his last slide, it was interesting to note that 22 in fact, NEI concurred with the elements that the staff is 23 proposing. Basically --
24 MR. NELSON: That's correct.
(3 25 MR. NELSON: -- to concur with the FRPCC 1._)
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243 l' subcommittee report-that the federal-government should 2' fund the purchase'of KI for States that.in fact, desire
,O.
3 KI. They also, agree _with the finding that',here t should-4 not be a requirement on the States. So basically I think 5 it's one of those rare instances where NEI.and NRC, on a 6- rulemaking, is in parallel.
7 I'd like to also mention, there was some 8 question as to adequate protection. I recognize that that i
9 was a loaded question and naturally I want to stay away \
i
~
10 frpm as many loaded questions as possible. I just wanted e
$ 11 to clarify something. l 1: When the 1980 emergency planning regulations 13 were written, there's a finding that NRC must make for
~O
! 14 every plan, and that finding is that there be reasonable j i
15- assurance that adequate protective actions can and will be
't ;
4
- 16 taken, as a result of these emergency plans.
4 is 17 So that's what Alan -- that's sort of the ;
18 background as to why we focused on adequate protection. l t
19 It's really.a finding that there's reasonable assurance i
20 that that can and will be taken. Now, that then goes to, l 21 a plant can be closed, can be shut down if in fact, that f v
22- finding cannot be made.
i 23 Now you get closer and closer to the concerns i
24 of a State; if I have this, can I still have that finding :
25 that adequate protection can and will be taken? In other !
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I 1 244 words, if I cannot distribute it -- again, getting back to 1
~s 2 the implementing concerns that Alan focused on and that
. s
() 3 most states concern themselves with.
4 Again, it's the staff position that we do what 5 the federal government should do -- is to purchase it for 6 the States. What the implementing procedures from then on 7 are the concerns of the State and the public and their 8 responsibilities to the public.
9 MR. NELSON: It's not just a simple, you know, 10 here's the funds, go buy it. You know, the State and the 11 Local first of all, needed to make a commitment, develop 12 the plans and procedures, do the training and so forth, to 13 adequately satisfy -- as I identified -- the appropriate 79 /
x/ 14 criteria that's already in place.
15 And in the case of Tennessee they've done 16 tnat; although you can see the program in itself may have 17 little value because the KI's not there for them to 18 actually utilize. You know, they've either lost it or 19 can't find it, or you know, don't want to go pick it up.
20 But the first step is, hey, we have to 21 recognize it and then develop the program to allow -- the 22 purchase of it itself is nominal. I mean, that's the 23 least of it. The expense of developing the plans and 24 procedures, integrating it into your program-at-large is a
,em
( ,)
25 huge, you know, expense, and the cost-benefit for that may NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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245 1 be little in return.
2 CHAIRMAN SEALE: Yes.
73 Nj The last statement, Alan had 3 MR. JAMGOCHIAN:
4 alluded to the fact that the interest in KI has surfaced 5 primarily because of Chernobyl. Just to add to that, KI 6 was strongly recommended by the Kennedy Commission at the 7 TMI.
8 Chernobyl did not raise the issue; it was 9 raised at TMI as a result of the federal government trying 10 to find KI, and a manufacturer starting to work 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a 11 day while TMI evolved. So clearly, the intent here is to 3 12 be in better shape than we were after TMI.
13 The last point is, relative to the interests
~
I s
\/ -
14 of the public in getting this KI that's available in the 15 State of Tennessee. This is human nature. We find this 16 with the use of the sirens. We required sirens right 17 after TMI -
ad every nuclear power plant up to ten 18 miles, primarily to ensure public notification within a 15 19 minute timeframe.
20 Well, two, three, four years after TMI people 21 were interested every time the sirens were tested. They 22 typically are supposed to call the State Police or at 23 least watch TV. Right after TMI there was significant 24 interest with the interaction between the public and the I p
(,) 25 State Police. As you move away from the event, less and NEAL R. GROSS !
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246 1 less people get concerned about the siren sounding.
3; 2 Once we had Chernobyl, more and more p sole 3 starting to interact with the State police when they 4 tested the sirens. So now I understand, in the State of 5 Maine, the biggest problem with the testing of the sirens 6 is that it adversely affects milk production in cows.
7 Well, again, you're getting away from -- more and more as 8 you move away from--
9 CHAIRMAN SEALE: Sure. I think we're all 10 familiar with that problem. Back in the days when we 11 supposedly had a civil defense program --
12 MR. JAMGOCHIAN: Right.
13 CHAIRMAN SEALE: -- the problem with sirens
_s
' ']
' 14 was recognized by everyone, and most of the time it was 15 people who wanted to be sure those damn things were shut 16 off so they wouldn't bother them. So that's human nature.
17 Mr. Roy Wight from the State of Illinois, now 18 has asked for time to talk to us.
19 MR. WIGHT: Good morning.
20 CHAIRMAN SEALE: Good morning. Thank you for 21 coming, sir.
22 MR. WIGHT: It's my pleasure to be here 23 because this is a fairly major decision that we're trying 24 to deal with, and have been trying to deal with. I'm in 7
( ,
) 25 my 12th year as the manager of the Office of Nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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247
) 1 Facility Safety i. Illinois. I come from a background of
~y 2 Nuclear Power.
1 : l l L,
( 3 Before I went to this particular job I was a l
4 principal management consultant to the construction 5 management President and Vice Presidents in three 6 different nuclear power plants. During that time we 7 developed the emergency plans for those particular 8 facilities.
9 Preceding that I was in the Nuclear Navy for 1
10 28-and-a-half years, graduated from the Naval Academy, got 11 my r.. aster's degree in Public Administration at American 12 University, commanded a nuclear submarine for four years, 13 commanded a squadron of 15 nuclear submarines, and spent
, S i( )
14 five years as the Deputy Director of the Strategic Systems 15 Project for the Polaris, Poseidon, and Trident Missiles.
16 So I've got about, you know, half-a-century of 17 this stuff behind me. And this job and this position in 18 Illinois is unique because I only have one priority; and I
19 that priority is to protect the public from the potential 20 dangers of the operation of nuclear facilities in the 21 State of Illinois.
22 Anything that we can to do assure that l l
23 protection is high on our priority list. And we've looked 24 at potassium iodide very carefully, and we developed a g
q,) 25 policy that we would like to, in all cases, move people NEAL R. GROSS COURT REPORTFRS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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. ._ ~ . _ . _ _ . . __ . _ _ . . _ . . . . _ . _ . _ . . _ _ _ . . . . .._. _ - . _ . _
i 248 l
- 1- out of harm's way if the risks of a release from one of j
- 1
-2 these facilities is high. !
t
. 3 KI in particular, is important to us because 4
i
.4 we must protect those' people that are assisting us in ;
. 5 moving the public~out of harm's way. We have 12,000
- 6. emergency workers that we train and provide the dosimetry i
-- and with potassium iodide, prophylaxis --in the' State i
7 j t
8 of Illinoisi ,
j 9 We also, our policy extends the distribution - !
l l 10 - redistribution-of KI to those workers, along with their !
I 11 dosimetry, through 220 dosimetry control offers that we ~!
l 12 also train, and we inspect, and we renew their supplies. l 13 Institutionalized people are located and a
- O 14 list of them are kept current, and we have plans and we l
i 15 demonstrate our ability to effect those plans when they're l r
f: (
l 16 needed.
f
. 17 Answering the question of KI has been j
- 18 difficult for us because most of our emergency workers are l 19 volunteers, and we don't require anything of a volunteer i-
[
20 except to follow our procedures, and they sign onto that. ;
1
.21 We recommend that the emergency workers and i t i 22 the institutionalized patients that can't be. moved, take i
. 23 KI in certain conditions. And those conditions are when-
~
- 24 the risk is high that an offsite release will occur that E{ 25 has radio-iodines present. Because if they do their job
, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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249 1 and stay there and perform those functions, they'll be
-~3 2 exposed to potassium iodide.
\
'~' And it is a voluntary suggestion and 3
4 recommendation that we make to the Governor and in turn, 5 to the Local governments, and they in turn, recommend to 6 their people that they make themselves available of this.
7 And we train them, not only in what this does 8 for them or could do for them protectively, but we also 9 train them in the potential downside so they could 10 recognize the symptoms if they were to appear after 11 ingesting this.
12 For the general public to be protected 13 adequately would require either redistribution or i \
\/ 14 distribution just prior to, and in the first few hours, 15 after a release of significance. Our intention in a fast-16 moving accident, is to recognize the risk as early as we 17 possibly can and evacuate the population that is most in 18 danger.
19 And we may do that in stages to perhaps, take 20 a look at the first few miles around a plant and evacuate 21 those geopolitical boundaries and then expand that out, 22 depending on the direction of the wind, whether there's 23 rain, and projected chanc,es in the weather, wind shifts 24 and the shores of Lake Michigan.
(ox_)
. 25 Fifty percent of the time traditional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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250 1 meteorology does not describe the dispersion patterns 2 because of the lake effects, but we know what those are 7 ~\
('"' )
3 and we can measure them, and we base our recommendations 4 on those facts. We tend to follow tire NRC's position that 5 the most effective emergency action is to recognize the 6 danger and move people from harm's way.
7 I have a statement here that talks to a lot of 8 these issues. We do recognize what the problems are.
9 Redistribution -- I have difficulty and I'm sure some of 10 you may have difficulty remembering where I put my allergy 11 pills when the spring comes, and five years of storage.
12 And we want the people to understand this and 13 they listen carefully when we train them, or if they even 14 attend training or even read what we distribute.
15 Do they really understand that this only will 16 protect you against one radio-isotope -- or maybe a 17 couple; there are several radio-iodines -- but it only 18 protects you from a very small segment of the radioactive 19 material that's going to be there, and certainly it's not 20 the most life-threatening, particularly in the early 21 stages.
22 MEMBER KRESS: What other radio-isotopes are 23 you referring to?
24 MR. WIGHT: Well, most of them that you see on i7,)
s_ 25 a fission fragment curve, Dr. Kress. We have a device in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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251 1 the plant's ventilation exhaust system, the main stacks, s 2 that take a suction on that and pull it down through an L 'i 3 unmanned device, and we measure those -- 50 of the most 4 important radio-isotopes to health effects.
5 And we have a radio-iodine station in that 6 machine that measures the radio-iodines that's going out.
7 Plus of the cesiums -- the full dog-eared curve is in 8 there if we want it.
9 MEMBER KRESS: If the risk studies I've seen 10 are correct, and if present strategies for dealing with 11 core-concrete interactions are successful, then we're 12 likely to see noble gases -- iodine, tellurium, and 13 cesium?
I') And we have a noble gas N 14 MR. WIGHT: Right.
15 station that measures all of those --
16 MEMBER KRESS: And the noble gases are --
17 MR. WIGHT: But not from the concrete core 18 interaction, of course.
19 MEMBER KRESS: Right. But of these things, 20 the tellurium is a problem because it becomes iodine, 21 cesium is a problem because it hangs around a long time 22 and produces a long-term dose, noble gases are a problem 23 because they give you a whole body dose as they pass by 24 and you breathe it in.
r' (N,) 25 The one that really causes a great deal of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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252 1 harm is the iodine. So this question, this issue of
~ 2 protecting against all the spectrum of radio-isotopes is a
( )
'~' little bit of a hollow comment, I think. I think what we 3
4 need is protection from the iodine.
5 MR. WIGHT: Most of our concern in the early 6 stages is predicting the gross gamma. If we have radio-7 iodines present we immediately put our emergency workers 8 into the prophylaxis situation by recommending that they 9 take it, but we are concentrating on moving the public 10 away from the danger before there is a release -- before 11 there is a core melt.
12 MEMBER KRESS: Yes, but part of that strategy 13 is you would, under some circumstances, recommend not i' I
' 14 evacuating?
15 MR. WIGHT: Very few. Only in those cases 16 where there is a known short release duration coming 17 vecause of the situation, or in those cases where the 18 weather conditions would preclude us from doing an -- and l 4
19 would be life-threatening to even try to move people in 20 those conditions.
I 21 MEMBER KRESS: And under those circumstances l 22 you would recommend shelter --
23 MR. WIGHT: Sheltering, recognizing that 24 sheltering doesn't do anything for you, much.
( 25 MEMBER KRESS: Right. Okay. Redistribution NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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253 1 has been sort of dismissed as a good strategy because of fN 2 the experience with TVA. That seems to me like it's one
\ '- )
3 data point, and part of the problem there is shelf-life, 4 but the other part of the problem is public education.
5 And I don't know what the problem is because -
6 - did anybody make a follow-on study to see why that was 7 an unsuccessful attempt at redistribution? Do people 8 understand why it failed? We know it did and the reasons 9 it did, is people didn't make widespread use of it. But 10 I'm not sure we know why.
11 MR. WIGHT: From my standpoint, the idea that 12 people, number one would, the general public would listen 13 carefully. We do a lot of training of communities and es I i
( / it's difficult to draw an audience on things that are of 14 15 immediate importance to them if there were a nuclear 16 accident.
l ', We try to work througn the emergency workers 18 because they have friends and families and that's a good 19 network. But to get their attention, number one, is very 20 difficult; to have them put it high on their priority list 21 and remember it is another problem.
22 And my real concern is they would have an 23 unfounded feeling of confidence that they were protected.
24 And they might say, I don't remember what this is but I q '
(_/ 25 remember it's a radiation pill and so I don't really want NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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254 1 to move out of my house; I'll just take my radiation pill 73 2 and stay there.
(v) 3 Even the French, I read in one of these 4 magazines --
5 MEMBER KRESS: How would you institute an 6 evacuation even if you didn't have potassium iodide? How 7 do you implement one?
8 MR. WIGHT: We have a group of local 9 government operating centers and we drill those people in 10 the evacuation -- notification and evacuation setting up 11 the --
12 MEMBER KRESS: Notify by radio and telephone?
13 MR. WIGHT: Yes sir, the emergency broadcast n
'- 14 system and --
15 MEMBER KRESS: Emergency broadcast --
16 MEMBER BARTON: And the sirens.
17 MEMBER KRESS: And you think people would say, 18 well, I'm not going to pay attention to all this l 19 notification to evacuate; I'm going to take my pill 20 instead?
21 MR. WIGHT: Well, I've known --
22 MEMBER KRESS: You think that's a real problem 1 23 -- l 24 MR. WIGHT: I've seen people on top of their
(,)
25 houses in floods and I've seen them still on the beach in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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255 i
1 hurricanes --
2 MEMBER KRESS: Well, you're always going to 7s
( )
G 3 have that.
4 MR. WIGHT: And that's what I'm concerned with 5 in this. I don't want to give anybody something that was 6 not really informed, another reason not to take care of 7 themselves. Yes sir.
8 MEMBER KRESS: It's another reason.
9 MR. WIGHT: Yes sir.
10 CHAIRMAN SEALE: George, did you have a 11 question?
12 MEMBER APOSTOLAKIS: No.
13 CHAIRMAN SEALE: Anyone else?
<w I ) Isn't titere -- don't k' 14 VICE CHAIRMAN POWERS:
15 the Swiss predistribute KI?
16 MEMBER KRESS: I don't know. Does anybody?
17 MEMBER BARTON: Does anybody know?
18 MR. MOHSENI: Aby Mohseni from AUD. The Swiss 19 did have a redistribution of KI in their homes tied to 20 concerns about World War types of events, and they 21 continued using that system of storage after the Cold War 22 was over. i 23 So that the placement of KI and the education 24 level, training level, was high on their list of ;
(o) ,
25 government officials, again due to the circumstances of NEAL R. GROSS i
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256 i
1 protecting the public against a nuclear war. And that n 2 level of education is clearly unique for the Swiss and it
! \
\"'/
- 3. wasn't available in other parts of Europe.
4 MR. WIGHT: I would add that I read in one of 5 the trade publications sometime in the last nine months, 6 that the French had delayed their commencement of the 7 program because they were dealing with problems of 8 distribution and effectiveness. I don't know the detail.s 9 of that.
10 CHAIRMAN SEALE: Very good. Any other 11 comments, questions? Anyone from the audience that would 12 like to make an additional observation or comment?
13 Well, I guess -- well, thank you very much.
(D
'd 14 MEMBER KRESS: Thank you.
15 CHAIRMAN SEALE: And your written statement, 16 by the way, is very helpful and I appreciate you bringing 17 that to our attention.
18 I guess you folks would kind of like to have a 19 letter from us, is that the gist of things?
20 MR. JAMGOCHIAN: Yes sir. That would be 21 great.
22 CHAIRMAN SEALE: I'm not sure we can do 23 anything for you at this meeting, but we may be able to do 24 something for you at the end of the next meeting.
h,S 25 MR. JAMGOCHIAN: Thank you very much.
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257 1 CHAIRMAN SEALE: Okay. We have an immediate -
2 - well, we'll decide what kind of letter. We have a need f3
( )
L .J 3 to go ahead and recess at this point, but sometime after 4 lunch I'd like for us to spend about ten minutes or so or 5 whatever, trying to decide exactly what kind of response 6 we'd like to prepare on this question.
7 MEMBER APOSTOLAKIS: John Szabo is here. I i 8 thought --
9 CHAIRMAN SEALE: Yes, we're going to -- we 10 thought what we'd try to do -- well --
11 MEMBER APOSTOLAKIS: Are we going to do it 12 here?
13 CHAIRMAN SEALE: Well, I thought what we'd try i
14 to do is pick up something downstairs and come back, and 15 then we can do that in one fell-swoop, so to speak.
16 MEMBER APOSTOLAKIS: Okay, very good.
17 CHAIRMAN SEALE: All right. We'll recess 18 until 1:15, I think is the time on the docket.
19 (Whereupon, a brief luncheon recess was taken 20 at 11:54 a.m. until 1:20 p.m.)
21 CHAIRMAN SEALE: Before we get started, I want 22 to make one comment. Someone was so very kind here as to 23 provide me with a supplementary sign that said, Number One 24 Arizona Wildcat Fan, and I appreciate that distinction. I
( ,) 25 found also that someone else saw fit to make the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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258 1 observation that a fan is a thing that goes around in r^S 2 circles and blows a lot of hot air. It's usually caged,
\
)
3 and rightly so.
4 I have problems with that, and so under those 5 circumstances I resorted to that ultimate reference, 6 namely the dictionary.
7 MEMBER KRESS: To aee what a fan was.
8 CHAIRMAN SEALE: Ar.tl in f act , the word " fan" 9 in this context is really a homophone of the word fan as 10 it's used in the other context. '" hey both are listed as 11 separate words --
12 MEMBER KRESS: Homophone has to be spelled
,_. 13 differently.
/ \
t.~' 14 CHAIRMAN SEALE: Well, it's a separate meaning 15 --
16 MEMBER KRESS: That's part of the definition.
17 CHAIRMAN SEALE: It's a separate meaning.
18 MEMBER KRESS: Separate meaning, that's okay.
19 CHAIRMAN SEALE: Okay, and in fact, it turns 20 out it's short for fanatic.
21 MEMBER KRESS: Okay.
22 CHAIRMAN SEALE: All right? All right. So I 23 think we've cleared that up now.
24 Before we adjourned we had heard the
(^N,
( _) 25 presentations regarding the potassium iodide question. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISL AND AVE , N W.
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259 1 have the Recorder here to help us keep track of what's 2 going on. We also have Mr. Nelson with NEI, and we have a J
3 young lady who's from one of the news services -- OPI News 4 Service -- who covers Illinois, who wanted to hear what 5 all we had to saying this particular arena.
6 So I thought we might spend about ten minutes 7 going around the room and trying to develop a preliminary 8 position and decide what it is we want to do. Now 9 apparently, the staff would very much like for us to write 10 a letter of some sort to the Commissioners -- I think we 11 would probably have that at the next meeting -- in which 12 we would convey to them our impressions based on what we 13 heard today.
! / Do you want to start in any
-' 14 MEMBER KRESS:
15 order here or just --
16 CHAIRMAN SEALE: No, I --
17 MEMBER KRESS: I'm willing to express an 18 opinion.
19 CHAIRMAN SEALE: All right; express.
20 MEMBER KRESS: In the first place, I'm on the 21 side of motherhood and apple pie.
22 CHAIRMAN SEALE: Yes, but how do you feel 23 about potassium iodide?
24 MEMBER KRESS: Okay. Number one, I think that (j)
I 25 potassium iodide can be a useful protection against HEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. '
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260 1 thyroid cancer, in children especially, and some adults,
,s 2 if administered before one gets a dose of radio-iodine.
( )
3 So technically, it's a defense that is viable and useful.
4 Now, the real problem with, say, using it as 5 prophylactic in the case of a ntclear accident to me, is 6 the distribution problem. I think distribution is a huge 7 problem, and I think the failed experience at TVA in 8 Tennessee was because they tried to have this thing 9 distributed to individual hor _e~ colds; that they would keep 10 on store and have available when needed at some future 11 time.
12 I just think that's a faulty distribution 13 strategy and just don't think that will ever work -- no 14 matter what the shelf-life is, no matter what education 15 you give these people, or what. I just don't think that 16 will ever work as a strategy.
17 Now, given that and given my perception that 18 there are probably instances that we may or may not be 19 able to envision ahead of time, where it would be very 20 nice to have some potassium iodide available, since we'll 21 have to have it for workers anyway and then for emergency 22 people, the question is, can we make that available and 23 then start worrying about the distribution problem?
24 And let the storage be under the purview of
/\
( ,) 25 the federal government, since they're going to have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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261 1 storage anyway. Have it reasonable amounts at reasonable zx 2 locations. And now the question is, how do you -- is it
( '~') '
3 useful to do that and can you get it to the general public 4 when it's needed?
5 I think that's a problem, of course, but it's 6 one that can be worked on. It's one we ought to think 7 about. So my position right now is, it would be a good 8 idea to stock potassium iodide under the purview of the 9 federal government -- regionally available or locally 10 available at all the plants -- but work on this 11 distribution problem because that's the bugaboo.
12 There's no real problem I think, with this 13 allergy question, there's no real problem with shelf-life t i
'- '/ 14 any more, there's no real problem with cost. The problem 15 is the distribution. So I recognize that as a problem; we 16 don't have a real solution for it right now, but I don't 17 think the -- in fact, I'm absolutely sure the solution is 18 not to predistribute it to households. I just don't think 19 that will ever work.
20 MEMBER SHACK: But in practical terms then, 21 you don't mind denying the petition and just going with 22 the current federal plan to stockpile it then?
23 MEMBER KRESS: I have a problem with it 24 because the current plans give the States the option, and
(,) 25 I really think the federal government ought to go ahead NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N.W.
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262 1 and stockpi'e it and have it available at every location, x 2 whether the States ask for it or not.
( )
V So I have a little bit of problem with it. I 3
4 think giving the States the option means some states will 5 opt for it and some won't, and some people will not have 6 the advantage of the coverage if it's possible to use it.
7 VICE CHAIRMAN POWERS: Tom, it sounds to me 8 like you're advocating a policy issue that seems somewhat 9 out of our purview.
10 MEMBER KRESS: It may be, yes.
11 VICE CHAIRMAN POWERS: The decision on whether 12 States stockpile or federal government stockpiles sounds l' like a political issue to me. e t :
\' '4 MEMBER KRESS: It tould very well be, yes.
15 VICE CHAIRMAN POWERS: And --
16 MEMBER KRESS: But it gets to the problem of 17 the distribution and the uneven coverage.
18 VICE CHAIRMAN POWERS: It seems to me that 19 those are technical issues --
20 MEMBER KRESS: Those are technical issues.
21 VICE CHAIRMAN POWERS: Okay. But how you 22 react to the technical issues gets you into a policy 23 regime. Right now I think we have to be careful how we 24 coach the language here so that we stay on the technical
(, 25 side and not on the political side.
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x 263 ,
j 1 MEMBER KRESS: Well, we give advice on policy. !
c 2 MEMBER APOSTOLAKIS: Yes, sure.
3 MEMBER KRESS: I don't see that-we should e
i- 4 avoid policy issues. I mean, we're primarily a technical 5 committee, but quite often we're asked for our opinion on -
6 things, and there's a lot of technical component to this j
' 7 but it's also a policy --- ,
8 VICE CHAIRMAN POWERS: I don't argue with that t
i
- 9 __
MEMBER KRESS: -- I'm not worried about giving 'i 10 i
11 policy advice.
I I
12 VICE CHAIRMAN POWERS: I'm not contesting.
13- MEMBER APOSTOLTKIS: One of the things that lO 14 bothered me -- and I think it's an issue and it's not just
! 15 the issue of distributing it -- it has to do with l i
16 perceptions. If you do things like that, that involve e 3 17 non-technical people, then it seems to me that you're ,
18 sending the message that this is something that will l,
! i 19 protect you against an event that has a pretty good l l,
20 probability of happening in the near future. ;
t 21 In fact, the gentleman from Illinois, Mr. ;
22 Wight, severall times used the words "high risk", and I l l
I 23 decided not to challenge him, but I really questioned that l i 24 statement that reactors pose high risk and that.you should be prepared for these accidents, you know, as if 25 I
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,z.. ....,,,._,.,-.w -.,c.,, % oe., , . , , . . . , , , . , , .
264 1 radioactivity is about to come next year.
2 So I think there is a problem with that too.
73
( l That it is not a minor problem, the issue of perceptions.
3 4 MEMBER KRESS: How different is the perception 5 with potassium iodide as it is with the whole concept of 6 an emergency preparedness plan? How are they different in 7 terms of image and perception?
8 MEMBER APOSTOLAKIS: Well, I'm at a 9 disadvantage here, Tom, because I really don't know the 10 details of what goes into measures of preparedness and so 11 on, but I know that what Mr. Wight was saying --
12 MEMBER KRESS: They have to have a plan around 13 every plant and they have to do regular drills and
\
'l
- 14 exercises --
15 MEMBER APOSTOLAKIS: The actual people -- I 16 don't mind if the professional people have these.
17 MEMBER KRESS: Oh, but all the locals -- and 18 it's all in the news and the local people --
19 MEMBER SHACK: All the petition says is that 20 those plans could include consideration of the use of 21 potassium iodide.
22 MEMBER BARTON: Potassium iodide. George, are 23 you going to bet -- current guidance is if you're in a 24 general emergency, where the NRC's coming from and what g)
(, 25 Utilities have taken on is that you get to a general NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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265 1 emergency, whether you've got the stuff spewing out there
,3 2 or not, you're to go into a protective action
\v) 3 recommendation which includes evacuation; around the plant 4 and at least five miles downwind.
5 That's where the plans are. And people are 6 drilling that, at least annually. At least annually you 7 get all the local people who are the volunteers 8 participate, and you run drills at night when all these 9 people are available, and that's what you go and do.
10 And in Jersey -- it's different in different 11 States, you know, who control the -- what State agency.
12 In Jersey it's the State Police. And they participate 13 every year. They actually send, you know, State Police
/ \
kI 14 out and they simulate evacuations and the whole nine 15 yards. So that's what they're talking about with respect 16 to detailed plans and procedures.
1 17 People need to be qualified for the positions.
18 And in a real event the NRC has a role and they've got 19 seats in certain emergency centers. It's a real big deal 20 and it's very formal, very proceduralized, and it's ;
21 exercised and practiced. And every so many years -- I 22 forget the frequency -- FEMA has to come in and evaluate 23 the State and Local agencies' performance in carrying out 24 their role, which is, you know, whatever you're doing.
n
(_,) 25 If you're evacuating people, how well they do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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266 1 it and how well each of the localities within the regions 2 affected performed their functions. And they're evaluated
~
3 on that as well. And they can fail and have to go back 4 and do, you know, drills to requalify themselves, to 5 recertify themselves that they can handle the emergency.
6 Having said all that, you know, potassium 7 iodide yes, it's good stuff, and it could help you. But I 8 think the real problem -- Tom's right -- is distribution.
9 How do you get it to everybody that's affected --
10 MEMBER KRESS: A substantial fraction of it.
11 MEMBER BARTON: Right. And you're not going 12 to be able to really do that so somebody is not going to 13 get it. Is it better that some people get it and some r
i 14 people not? Some States get it, some people not -- not in 15 some of the States don't, don't even stockpile it? I 16 don't know. Because the whole plan is premised on getting i 17 people out of there before you get the radio-iodine dose.
18 MEMBER SHACK: The only thing I see that's up, 19 the question now is the question of whether it should be 20 an option for the State to use it --
1 21 MEMBER BARTON: Or mandatory? l 22 MEMBER SHACK: -- or mandatory. I mean, the 23 current federal policy appears to be that they're going to 24 make it an option.
7
,) 25 MEMBER KRESS: If you were talking only the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
(202) 2344433 WASHINGTON D C. 20005-3701 (202) 234-4433
267 j l
1 difference between option and mandatory, that's one thing. l S
2 I'm talking whether or not the federal government ought 3 not to have stockpiles of these available and not give the 4 States an option or a mandate. The desire that --
5 MEMBER SHACK: The federal government will 6 have a stockpile; that seems to be a given at the moment.
7 MEMBER KRESS: Okay. Now let's work on the 8 distribution question. They will have a stockpile but 9 it's not for this purpose, and I don't like that idea. I 10 chink you ought to get them out of --
11 MEMBER SHACK: Whatever cover you use you have 12 it, right.
13 MEMBER KRESS: Well, but that's a pragmatist's f7_
\#
I 14 approach.
15 MEMBER SHACK: I'm a pragmatic guy.
16 MEMBER KRESS: That's better than nothing, but 17 I would prefer to say, let's stockpile this for the 18 purpose of use in nuclear accidents.
19 MEMBER APOSTOLAKIS: Being pragmatic is better 20 than that.
21 CHAIRMAN SEALE: Okay.
22 VICE CHAIRMAN POWERS: There are a couple of 23 things that I just can't resist saying. It seems to me 24 this is something that one can do a risk tradeoff on to
( ,/ 25 decide its viability, and I haven't seen that. It also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1%D RHODE ISUND AW.. N W.
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268 1 seems to be --
MEMBER KRESS: Unless one views it purely as
) 2
'J defense-in-depth, which is outside maybe, the purview of 3
4 the risk.
5 VICE CHAIRMAN POWERS: I agree with you on 6 that Tom, and we have always considered that emergency preparedness is outside the purview - is part of defense-7 in-depth and whatnot. I still think that the discipline 8
9 of doing risk tradeoffs and risk assessments is something 10 that I can't resist drilling in --
11 MEMBER KRESS: I just happen to think it would 12 be a waste of time in this case.
13 VICE CHAIRMAN POWERS: -- in this environment.
,s
/ i
'N 14 It's not clear to me that we're going to achieve any great 15 risk reduction, but certainly that risk reduction remains 16 unevaluated.
17 MEMBER KRESS: If we tried to justify this on 18 the basis of risk reduction, I think it's totally out the 19 window.
20 VICE CHAIRMAN POWERS: It's probably out the 21 window.
22 MEMBER BARTON: I think the distribution thing 23 -- it's worked on it, and I really don't think you can 24 solve it.
p MEMBER KRESS: Well, it may be an insolvable c/ 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
WASHINGTON. D C, 20005-3701 (202) 234-4433 (202) 2344433
269 1 problem, but it doesn't look insolvable to me. l
,- 2 VICE CHAIRMAN POWERS: The other point that I
~'
3 think that the issue has taken on a higher visibility in 4 light of recent events at Chernobyl, and I think that's an 5 unfair comparison because we have a population in this 6 country whose dietary iodine probably leaves them well 7 blocked in contrast to Chernobyl.
8 MEMBER KRESS: Yes, I think that's a 9 reasonable thing to address. I would be very suspect if 10 that's the case for children, and children are one of the 11 people --
12 VICE CHAIRMAN POWERS: It would not.
13 MEMBER KRESS: -- we want to really protect 4
t
'\~# 14 here.
15 VICE CHAIRMAN POWERS: They're the ones that 16 are most likely to be not properly blocked, not fully 17 blocked, but they'll be heavily blocked -- we have a 18 tremendous amount of iodine if our diet in this country.
19 MEMBER KRESS: Clearly, you could dismiss the 20 need for this on the basis for risk. You could almost 21 surely dismiss the need for emergency response on the 22 basis of risk. Maybe not.
23 VICE CHAIRMAN POWERS: We've been through that 24 exercise and convinced ourselves that we didn't want to go
/m
' ,)
25 any further in that because we viewed it simply as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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270 1 defense-in-depth, and it was not there.
,cx 2 When it comes to the area of our distribution lV i 3 and whether that's successful or not, I harken back that I 4 did happen to be in Switzerland in a private home and the 5 cubject did come up.
6 And they said oh yes, we have ours and they 7 immediately went to the medicine chest and pulled it out 8 so that I could see it an admire it, and read all the 9 warnings on it written it 15 different languages as they 10 have to in Switzerland. And I was very impressed.
11 But I will concede that there's a translation 12 problem to a less visibleness, less well-educated, less 13 homogenous population in this country. But I'm not
(,)
'/
'- 14 persuaded that if I could establish any rational need for 15 this iodine -- which I am -- I can't and I've seen nothing 16 to do it, that the distribution problem could be overcome.
17 MEMBER BARTON: It's nice that you were at 18 their home and they could take you to their medicine 19 chest. Suppose this lady is at the mall five miles from 20 home at the time it happens and evacuates? She gets in 21 her car and her State cop right at the exit of the mall, 22 directing on her on Interstate 195. Where's her KI 23 tablets on the medicine cabinet?
24 MEMBER KRESS: Well, you have to ask yourself,
(/ 25 what is the measure of success? And does it mean every NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 2344433 WASHINGTON, D C. 20005-3701 (202) 234-4433
271 1 single person has to get it? No , it doesn't mean that.
- 2 MEMBER SHACK: I thought a third was pretty 7
() 3 good.
4 MEMBER KRESS: A third would be pretty doggone 5 good, in my opinion, yes.
6 MEMBER APOSTOLAKIS: Again, I'm a little bit 7 confused, though. You cannot justify it in terms of risk 8 tradeoffs.
9 MEMBER KRESS: I'm sure you can't.
10 MEMBER BARTON: Oh yes, that's right.
11 MEMBER APOSTOLAKIS: So this then, is a 12 manifestation of defense-in-depth.
13 MEMBER BARTON: Yes.
14 MEMBER APOSTOLAKIS: And I come back to my 15 point, and there are negatives, side effects, that scare 16 people.
17 MEMBER KRESS: Are you really worried about 18 scaring people --
19 MEMBER APOSTOLAKIS: I think perceptions --
20 MEMBER KRESS: -- and how --
21 MEMBER APOSTOLAKIS: -- run this business.
22 Perception run this business. They brought it to its 23 knees. So now you're going out and distributing this 24 thing and saying in case this accident happens --
m
(_,) 25 MEMBER KRESS: I'm pretty sure --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
9 02) 234-4433 WASHINGTON, D C. 20005-3701 (202) .W433
272 1 MEMBER APOSTOLAKIS: -- to the minus 6 or 7 --
n 2 MEMBER KRESS: I'm pretty sure that's a very i i q,
3 high element -- level of concern of the industry. I'm 4 pretty sure that would be high on their --
5 MEMBER APOSTOLAKIS: Perceptions?
6 MEMBER KRESS: Yes.
7 MEMBER APOSTOLAKIS: Yes, and it should be.
6 It should be. No, but I mean, if you cannot justify it in 9 terms of risk estimates --
10 MEMBER KRESS: But are we going to trade off a 11 potential for protection that the perceptions --
12 MEMBER APOSTOLAKIS: Yes. Because perceptions
,_s 13 can cause psychological trauma. Yes, if a mother feels
/ \
A"l 14 that her children are under, you know, the threat of a 15 nuclear accident --
16 MEMBER BARTON: You come to my house and say, 17 these are for your kids in case -
18 MEMBER APOSTOLAKIS: Yes.
19 MEMBER BARTON: -- Creek has an accident over 20 there --
21 MEMBER APOSTOLAKIS: Yes.
22 MEMBER BARTON: The next thing I'm going to do ,
l 23 is call my realtor. ,
1 24 MEMBER APOSTOLAKIS: Yes. And the other
,r x
(_,) 25 things is that you cannot really say that it's the same i
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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273 1 thing as evacuation.
-s 2 MEMBER BARTON: Right.
~
3 MEMBER APOSTOLAKIS: Because people are used 4 to evacuation. Somehow, you know, a lot of people do that 5 and they say, okay, evacuation makes sense. But to give 6 them a tablet of potassium iodide, wow. Well, I think 7 that's a disservice to them.
8 MEMBER KRESS: You're mixing a little bit, the 9 things up here. One is, preceding my comments as saying, 10 I didn't think redistribution would work. Dana gave me 11 some evidence that indicated he thought it might. But my 12 point was, you have this stuff available at the centers 13 run by the federal government, and then you figure out a
(~';
14 way to distribute it when you need it.
15 MEMBER BARTON: Wait a minute. What centers -
16 -
17 MEMBER KRESS: And that doesn't -- I don't --
18 MEMBER BARTON: You said the new bureaucracy 19 of federal government centers within a 10-mile EPZ.
20 MEMBER KRESS: I don't know. The federal 21 government has a center in every city in every country in 22 the world.
23 MEMBER SHACK: VA hospitals.
24 MEMBER KRESS: VA hospitals, Post Offices --
,m
() 25 whatever. I mean --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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274 1 MEMBER SHACK: That's easy.
2 MEMBER KRESS: It's easy; we can figure this L3 out. But it's a question of whether you give it to'them 1 4 ahead of time or you have it-ready and figure out how to 5 give it to them when it's needed. And is that possible?
~
6 MEMBER APOSTOLAKIS: In the name of defense-
- 7. in-depth.
I 8 MEMBER KRESS: In the name of defense-in-l 9 depth, yes.- 1 j
10 CHAIRMAN SEALE: Well, I -- i 11 MEMBER APOSTOLAKIS: I am very skeptical.
12 MEMBER SHACK: I claim that's basically going 13 to happen no matter what. .
MEMBER KRESS: You may be right, but why don't I 14 15 we make it obvious, clear, and say that's the way it ought 16 to be, and whether it happens or not we're on record of
- - 17 saying what the ACRS thinks.
18 MEMBER APOSTOLAKIS: Actually, if it happens 19 anyway I'll let it happen, but I would not tell them that 20 this is the way it ought to be.
21 MEMBER KRESS: You wouldn't fight against it 22 because of this perception problem?
23 MEMBER APOSTOLAKIS: I.wouldn't fight against f
.24 it. ;
, 25 MEMBER KRESS: So you're not very concerned NEAL R. GROSS [
COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W. ;
- (202) 234 4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 ,
275 7
- 1 the perception --
2 MEMBER APOSTOLAKIS: No, I think the whole O 3 country is run based on perceptions. I mean, look how we 4 spend money on risks, j i
5 MEMBER KRESS: I understand.
l 6 MEMBER APOSTOLAKIS: How much money we're 7 spending on nuclear risks and how much money we're 8 spending on risks that are based on statistics, not on j I
9- calculations. It's completely irrational. But t-hen 10 again, I'm not running the country, so.
11 VICE CHAIRMAN POWERS: Much to your chagrin.
12 CHAIRMAN SEALE: All right. So what kind of a
. 13 letter do you guys want?
14 MEMBER KRESS: My proposal is a Jetter in 15 favor of stockniling it by the federal government, to 16 disavow this option --
l 17 VICE CHAIRMAN POWERS: Would you be willing to l l
18 include in the letter, statements to the effect that this 19 is indeed, a defense-in-depth and cannot be justified l 20 based on risk?
21 MEMBER KRESS: Absolutely; or a cost benefit.
22 VICE CHAIRMAN POWERS: Or a cost benefit.
23 CHAIRMAN SEALE: That's a good --
24 MEMBER KRESS: Actually, I'd be willing to put I
25 those --
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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276 3 1 MEMBER APOSTOLAKIS: Then the committee.will !
t p .2 endorse-that?. [
1
\' . MEMBER KRESS: I don't know.
~
I'm just f 3
4 proposing.
I 5 MEMBER APOSTOLAKIS: Are there other memb'ers f i
6 of the committee -- ;
7 MEMBER KRESS: I propose the committee-dispose l 8 it. ;
l 9 MEMBER APOSTOLAKIS: What do you think? ' Bill 10 wants to say something. !
l 11 MEMBER SRACK: No. I mean, I support the idea !
12 that it's a good idea from that point of view. But like I j 13 said, I think it's a moot point. It's going to happen. ;
o 14 The real question is whether you go further and make them l
15 included in the emergency planning. I i
16 MEMBER BARTON: Well, what's going to haopen? f 17 MEMBER SHOCK: It's going to be stockpiled. s 18 CHAIRMAN SEALE: Well, what do you mean by (
19 make them included in the emergency plan? l 20 MEMBER KRESS: Yes, I would not go that far -- )
i 21 MEMBER SHACK: Oh, okay. {
22 CHAIRMAN SEALE: I wouldn't do that. No way.
23 MEMBER SHACK: Then we agree. So you deny the ,
24 petition and we just endorse the staff position? l 25 MEMBER KRESS: No , no. I'm not quite f i
NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE., N W. ;
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277 1 endorsing it. I want them to --
MEMBER SHACK: You want them to get rid of (g 2 Q,]
3 that terrorist --
4 MEMBER KRESS: Yes. I want them to -- they 5 can leave that in there -- it's an "and" and not a -- see 6 that's not -- that's funding out of another pot. I want 7 it to be explicit what this is for.
8 MEMBER SHACK: Hey, you're an engineer; you 9 just get the job done. However it gets done, don't worry 10 about it.
11 MEM3ER KRESS: Oh, I don't know. I want it 12 done --
13 MEMBER SHACK: Duct tape is good enough.
l )
'd 14 MEMBER KRESS: I want it done right and above 15 board.
16 VICE CHAIRMAN POWERS: A major problem with 17 research at Argonne, I can tell.
18 MEMBER KRESS: That would be my proposal.
19 CHAIRMAN SEALE: Okay. Anybody else want to 20 add anything to it?
21 MEMBER APOSTOLAKIS: What is the proposal, 22 again?
23 CHAIRMAN SEALE: To agree that -- we recommend 24 that they deny the petition; that they proceed with the n
(,)
i 25 recommendations of the committee; however -- of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
(202) 234-4433 WASHINGTON D C. 20005-3701 (202) 234 4433
e 278 1 subcommittee, whatever that -- I'll find it and --
(
2 MEMBER APOSTOLAKIS: Oh, this federal --
1
,n) v 3 MEMBER SHACK: The federal -- yes.
i CHAIRMAN SEALE: Yes, the federal things. And 5 the fact that the federal government retain responsibility 6 for stockpiling it, and the distribution problem needs to 7 have further examination.
8 MEMBER KRESS: That's a good characterization 9 of what --
10 VICE CHAIRMAN POWERS: And that we acknowledge 11 none of this can be justified based on risk.
12 CHAIRMAN SEALE: That's right, yes.
13 MEMBER KRESS: That's a pretty good
[
14 characterization of my proposal.
15 CHAIRMAN SEALE: Okay. All right. We'll have 16 a draft of that for your next time.
17 MEMBER APOSTOLAKIS: This enhances the move 18 toward risk-informed regulation.
1 19 CHAIRMAN SEALE: Yes, it does. l 20 VICE CHAIRMAN POWERS: No, I want to put the 21 thing, it can't be justified by risk and hasn't been 22 attempted to, to point out that they are not pursuing a I l
23 policy of risk-informed regulation. l l
24 CHAIRMAN SEALE: Well, is it all right if the l 25 Chairman has additional comments --
l NEAL R. GROSS I
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE. N W. l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234 4433 1
1
279 1 MEMBER SHACK: The committee's never been 3 2 against defense-in-depth.
)
3 MEMEER KRESS: It's all right if anybody has 4 additional comments.
5 VICE CHAIRMAN POWERS: What are your 6 additional remarks going to be?
7 CHAIRMAN SEALE: I think the whole thing is a 8 --
9 VICE CHAIRMAN POWERS: Crock.
10 CHAIRMAN SEALE: -- crock. What are you doing 11 to do when you have the entire committee sign us on to 12 your additional --
13 CHAIRMAN SEALE: We'll get you a draft. Okay.
s }
'v' 14 That will take care of it for now.
15 (Whereupon, the 440th Meeting of the ACRS was 16 concluded at 1:47 p.m.)
17 18 19 20 21 22 23 24 A
\ ) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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4 V CERTIF.ICATE l'
This.is to certify.that the attached i proceedings before the United States Nuclear Regulatory. Commission in the matter of:
l Name of Proceeding: 440" ACRS l
Docket Number: N/A Place of Proceeding: ROCKVILLE, MARYLAND l were held as herein appears, and that this is the original j l
- transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to O typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
M /b1 TORBE W RINER Official Reporter Neal R. Gross and Co., Inc.
4 4
4 E
l 4
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- hTAL R. GROSS
- COURT REPORTERS AND TRANSCRIBERS 1323 RIlODE IStAND AVENUr, NW (202)234 443.1 WASIIINGTON,DC. 20005 (202)234-4433 1
w
, INTRODUCTORY STATEMENT BY THE'ACRS CHAIRMAN <
440TH MEETING, APRIL 3-5, 1997 i l
l l
THE MEETING.WILL NOW COME TO ORDER. THIS IS THE SECOND.DAX OF THE
- 440TH MEETING OF THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS. DURING TODAY'S MEETING, THE COMMITTEE WILL CONSIDER THE FOLLOWING
- I 1
(1) BORAFLEX DEGRADATION IN SPENT FUEL POOL STORAGE RACKS 1 (2) USE OF~ POTASSIUM IODIDE AFTER A SEVERE ACCIDENT i (3) FUTURE ACRS ACTIVITIES !
(4) PROPOSED ACRS REPORTS >
4 l
i' I
THIS MEETING IS BEING CONDUCTED IN ACCORDANCE WITH THE PROVISIONS OF l THE FEDERAL ADVISORY COMMITTEE ACT.
MR. SAM DURAISWAMY IS THE DESIGNATED FEDERAL OFFICIAL FOR THE INITIAL :
I PORTION OF THE MEETING.
WE HAVE RECEIVED A REQUEST FROM EPRI FOR TIME TO BRIEF THE COMMITTr:E ON EPRI ACTIVITIES ASSOCIATED WITH BORAFLEX DEGRADATION. WE HAVE RECEIVED :
WRITTEN COMMENTS FROM MR. PETER CRANE REGARDING THE ITEM ON THE USE OF I POTASSIUM IODIDE AFTER A SEVERE ACCIDENT. THESE COMMENTS HAVE BEEN DISTRIBUTED TO THE MEMBERS, AND WILL BE MADE PART OF THE RECORD OF TODAY'S MEETING. WE HAVE ALSO RECEIVED REQUESTS FROM THE NUCLEAR ENERGY INSTITUTE AND THE STATE OF ILLINOIS FOR TIME TO MAKE ORAL STATEMENTS REGARDING THE ,
ITEM ON THE USE OF POTASSIUM IODIDE AFTER A SEVERE ACCIDENT.
A TRANSCLIPT OF PORTIONS OF THE MEETING IS BEING KEPT, AND IT IS REQUESTED THAT THE SPEAKERS USE ONE OF THE MICROPHONES, IDENTIFY THEMSELVES Alm SPEAK UITH SUFFICIENT CLARITY AND VOLUME SO THAT THEY CAN BE READILY HEARD.
l
i NRR STAFF JRESENTATION TO THE ACRS i
SUBJECT:
BORAFLEX PROBLEM IN SPENT FUEL STORAGE POOLS i DATE: APRIL 4,1997 :
PRESENTER: LAURENCE KOPP i -
BRANCH /DIV: REACTOR SYSTEMS BRANCH /DSSA :
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(2) DESCRIPTION OF PROPOSED ACTIONS TO CONFIRM SUBCRITICALITY MARGIN FOR LIFE OF RACKS OR CORRECTIVE ACTIONS (2) DESCRIPTION OF PREVIOUS OR PRO, POSED FUTURE MEASUREMENTS
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- UNTIL REANALYSIS COMPLETED O '
E CONTINUED SURVEILLANCE THRU BORAFLEX COUPON SURVEILLANCE PROGRAM / BLACKNESS TESTS / SILICA LEVEL TRENDS / BORON-10 ASSAY (EPRI BADGER) s 5 CONSIDERATION OF EPRI RACKLIFE COMPUTER PROGRAM O ,
W' CURRENT CRITICALITY CRITERION E
O ly LESS THAN OR EQUAL TO O.95 WHEN FLOODED WITH UNBORATED WATER, INCLUDING ALL APPROPRIATE ~
UNCERTAINTIES AT THE 95% PROBABILITY / 95%
CONFIDENCE LEVEL .
i j PROPOSED CRITERIA t
E ly LESS THAN 1.0 WHEN FLOODED WITH QNBORATED
- WATER, INCLUDING ALL APPROPRIATE UNCERTAINTIES AT l THE 95% PROBABILITY / 95% CONFIDENCE LEVEL
) E k,,, LESS THAN OR EQUAL TO 0.95 WHEN FLOODED WITH j BORATED WATER, INCLUDING ALL APPROPRIATE i
UNCERTAINTIES AT THE 95% PROBABILITY / 95%
, CONFIDENCE LEVEL
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oCoNEE i OCONEE 2 OCONEE 3 PAUSADES POINT BEACH PRAIRIE ISLAND i
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_.. - .._ _- --_.--- , . -- ,r - -__ _ -
O O O ?.
RES PROPOSED RESOLUTION TO PETITION FOR RULEMAKING (P.M. 50-63) TO REQUIRE AVAILABILITY OF POTASSIUM IODIDE FOR USE BY THE GENERAL PUBLIC AFTER AN ACCIDENT ACRS Meeting Presented by:
4/4/97 Mike Jamgochian, RES 415-6534 i
_ _ _ _ _ -___._m__ .__ _ -__ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ , _ _ _ __-.___________________________._____.__________._____m - . _ _ . - -
BACKGROUND 1989 Differing Professional Opinion (DPO) requesting re-evaluation of NRC policy regarding use of KI after an accident. '
SECY-93-318 and SECY-94-087 attempted to resolve DPO by making KI available to states.
1 Staff proposed resolution failed by a 2-2 Commission vote.
SEPT. 9,1995 Petition for Rulemaking (PRM 50-63) submitted to NRC to require the use of KI as an emergency planning protective action (10 CFR 50.47)
Mid 1996 the Federal Radiological Preparedness Coordinating Committee (FRPCC) convened an ad-hoc subconunittee to re-evaluate Federal KI policy.
FRPCC sub-committee conducted a public meeting on KI in June 1996.
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___-_-____._____m ___-_____________ ____r__- ___ _ . _ _ _ _ _ _ _
O O O L
BACKGROUND (continued)
FRPCC sub-committee concluded its report on KI use for the general public. '
On October 24,1996, the FRFCC full Committee voted to concur with the sub- -
committee's recommendations. -
A Federal stockpile of medical supplies, which includes KI, has been established in two states and is being expanded for response to terrorist events.
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.m l
l l 2 .
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O O
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O .
FRPCC SUB-COMMITTEE REPORT Federal Government should fund the purchase of a KI stock pile for States.
1985 KI policy should be softened to be more flexible and balanced.
That localjurisdictions may consider the use of KI for the general public.
t 3
SUMMARY
OF PUBLIC COMMENTS s ON PETITION FOR RULEMAKING 63 public comments were received.
Support.for petition from:
5 Environmental Groups Members of the public American Thyroid Association One video tape Opposition to Petition from:
- 20 Utilkties 9 State Government Agencies 2 Utility Interest Companies 1 Lettbr signed by 12 Health Physicist 2 State Universities 1 Member of the public 4
O O
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STATUS OF PROPOSED RESOLUTION TO PETITION FOR RULEMAKING (PRM 50-63)
Have received comments and concurrence from all offices except one. -
Being reviewed by the ACRS. .
To be reviewed by the CRGR.
Final proposed staff resolution to the EDO by May 30,1997.
b P
5-
O O O ELEMENTS OF PROPOSED
- FRPCC FEDERAL KI POLICY (1997)
Stockpiling or distribution of KI for use by emergency workers, institutionalized individuals and the General Pooulation.
J Stockpiling and use of KI for the General Public at the discretion of States.
Federal Government will provide funding to States for an adequate supply of KI.
- Implementing details are still being negotiated within the FRPCC. ,
6
-r > --re v e - -- ,,
O O O .
3 CONCLUSION Deny Petition for Rulemaking.
- 1. Rule change not required when advising states of the availability of Federal funds to purchase KI as well as terrorist event stock piling.
Endorse the FRPCC 1997 Policy Statement on " Distribution of Potassium Iodide Around Nuclear Power Sites for Use as a Thyroidal Blocking Agent."
7
_ _ _ _ _ _ _ _1
- 4 j 4
O c
l ADVISORY COMMITTEE ON i REACTOR SAFEGUARDS i
i I
i
! Stockpile of Potassium lodide and Use By the General Public in a Radiological Emergency lO l
i 1
Industry Perspectives April 4,1997 l
. 1 Alan Nelson
- Nuclear Energy Institute I
O l glsi
!O INTRODUCTION l
l Nuclear Industry's Emergency i Response capabilities have matured over the past 26 years
- High level of emergency preparedness O
- Response technology
- Accident analysis and assessment capability
- Emergency planning expertise O 4 g
- p. .
L.
EMERGENCY PREPAREDNESS O REGULATORY ROLES l
Nuclear Regulatory Commission (NRC)
- Statutory responsibility for radiological health and .
safety of the public
! Feceral Emergency Management l Agency (FEMA)
- Lead role in assessing offsite planning and fO preparedness; makes findings of adequacy l
Environmental Protection Agency (EPA)
- - Establish protective action guidelines
! - Provide assistance in the development of emergency response plans j - Establish radiation detection and measurement systems l0 l
2 gi u - - -
l EPA PROTECTIVE ACTION O GUIDELINES l
l i
i EPA issued its final guidance on
! protective action guidelines (EPA 400-
- R-92-001, May 1992)
- EPA agreed with FDA that use of KI has iO been identified as effective i
EPA notes, " evacuation anc sheltering are, however, preferrec alternatives for most situations because they provide protection for the who e bocy and avoid the risk of misapplication of potassium iodide" O
3 fi
I STOCKPILING O POTASSIUM IODIDE (KI) i 1
4 t
Current policy - July 24,1985
! i
! - Predistribution or stockpiling of K1 for use by the
- O general public should not be required l - Decision on the use of KI for the general public
- during an actual emergency is the responsibility of l the State and, in some cases, local health authorities 1 i i
i
.O 4
fi
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.O REVIEW ACTIVITIES NEl submitted white paper -
Review of Federal Policy on Use of Potassium lodide (December 7,1993) I 1
- Paper evaluates
- I
! - Federal policy considerations
- Chernobyl implications
! - Source term work l0
- EPA Protective Actions Guidelines
- Industry Experience
- - Industry perspectives l
Industry strongly urged the NRC to retain its current policy as providing adequate protection
- of public health and safety Commission vote noted in SECY-94-087:
Retain the current policy which "does not i recommend requiring predistribution or O stockpiling for the general public" i
s gi
'o EUROPEAN KI DISTRIBUTION i
) KI distribution in Europe is a fairly common practice, but is not a valid reason for changing
- U.S.. policy i
l There are significant differences in the level of U.S. and European preparedness l
- Organization
! - Training / exercises O - Regulatory Oversight
- Facilities l
b
- Equipment U.S. Preparedness stresses capability for rapid i notification and evacuation if needed i
- Review of Chernobyl indicates Kl would be of less benefit in the U.S. due to the additional protective features of our preparedness programs lO e ,ggi
V E FRENCH Ki DISTRIBUTION lO TO THE PUBLIC i
l t
! Purpose was to reassure the hundreds j of thousancs of residents living near l French nuclear power plants l Despite the French government's good lO intentions, some resicents find it i unnerving - it is as though their leac ers j consider a nuclear accident inevitable l
l Having the pills "in hanc" will comfort i resicents who have little conficence in I
the French government's aaility to deal
[
with a nuclear accident l
4
)O l 7 di i
o INDUSTRY EXPERIENCE i
As a result of the Three Mile Island accident, the l State of Tennessee decided to predistribute KI i to residents within five miles of the nuclear power station The lessons learned from this experience l regarding the administration and cost of either
. stockpiling or predistribution of Kl should be considered in the reevaluation of the current
!O Policy l - 1981 -- KI distributed to 66% (3,022) of
! households (5,591) at a cost of $125,000
[ - 1984 -- Kl should be picked up at identified i
reception centers -- 32% of households j responded
- 1992 --less than 10% of households
- responded
- Combined validity of program is questionable
- Disposal of thousands of out-of-date vials
- has created additional administrative burdens and costs iO a g,
O INDUSTRY PERSPECTIVES I
i
! Current U.S. radiological emergency preparedness programs have
- demonstrated an acceptable state of i
- emergency preparedness capable of
- adequately protecting the health and l safety of the public l
The inc ustry's emergency res aonse l0 l capabilities have maturnd as the result l of 26 years of experience
! Over the past 17 years, annual exercises and actual nonradiological
! events have tested the adequacy of l these programs NRC and FEMA have proviced findings
~
of reasonable assurance O
(-,
! PETER CRANE ;
i O KI RULEMAKING PETITION i
- Petition recommends that 10 CFR 50.47 !
be amended to incluce the use of 1 p tassium iocide among protective O actions for the aublic l
l ,
i 4
i :
!O so .gpi
O COMMENT LETTERS 8
l
~
! NRC received 59 comment letters l - 22 commenters urged the NRC to support ,
the petition: six citizen groups and 16 !
O individuals favored the proposed rule
- 34 commenters urged the NRC to deny the petition: nine state agencies,21 utilities, and NEl opposed changes that would require stockpiling potassium iodide 44 g
o STATE COMMENTS i
i States objected to the petition
! Against potassium iodide distribution for the following reasons:
I
! - Distributing KI during an evacuation will increase the time required to complete g the evacuation l i
l - Distributing KI will result in allergic i
reactions
- Stockpiling would put additional burden
- on resources l - Mix of radionuclides is likely to contain more long-lived and potentially health
! threatening nuclides than radiciodides i
'O
I STATE COMMENTS O
(Continued) j i - Question predistribution and retention to i permanent, seasonal, and transient residents:
Would they be kept by households?
Could they be located in an emergency?
What percentage of households would i have to demonstrate ready availability to i
O satisfy federal requirements? l l
l - States agreed that most effective protective i measure is to evacuate based on plant l l conditions prior to any release of radioactive i material 4 ;
4 l - Some states indicate that state policy will continue to be against distribution of KI to i the general public I
O u
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o INDUSTRY COMMENTS i
- As a protective action for general public stockpiling or predistribution will not add any l significant benefit to the adequate level of protection currently provided
- Industry supports NRC's May 6,1994, i decision to maintain current policy to '
i provide K1 to emergency workers and institutionalized persons, but not lO recommend predistribution or stockpiling for l the public l
l Industry supports issuance of supplement 3, NUREG-0654/ FEMA-REP-1, Rev.1, j " Criteria for Protective Action
! Recommendations for Severe Accidents"
- - Emphasis on use of evacuation as the l primary and preferred protective action
- during a severe reactor accident at a nuclear power plant
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FRPCC - KI AD HOC i O SUBCOMMITTEE 1
~
Inc ustry Supports Subcommittee l Evaluations ,
- September 15,1994 l
Current policy should not be changed
- Federal government should not stockpile j KI for use by the public FEMA survey - 33 of 43 responding
- O states were opposed to a K1 stockpile program -
l
- October 3,1996 Federal Government agrees to fund the l purchase of Kl for any state that
! incorporates its use for general public
! Agrees that KI not be required
- Local governments should consult with their state and, if appropriate incorporate 4
into the planning process O
, i is i
!o CONCLUSION l
4 4
!~
4 Events that have occurred and studies
- performed since the 1985 Federal policy l l make a strong case for maintaining the current policy l0 - Industry recommencs that the NRC
- recognize state and local authority to !
l provice for aublic health anc safety 4
- Industry recommends that the NRC i
reaffirm their position to not require
- stockpiling or predistribution of KI for the
. public for nuclear power plant emergencies lo
- 4. .g.
-- -g - _ .. ._, _ _.
q.. .
- O REGULATORY FRAMEWORK Protective Measures l i
1 l
- 10 CFR 50.47 - Emergency Plans 1 l
.(b) The onsite and offsite emergency response plans for nuclear power reactors must meet the following standards:
(10) A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and ,
- the public. !
NUREG 0654: FEMA-REP-1. Rev.1 II. Plannina Standards and Evaluation Criteria J. Protective Response - Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place.
J.7. Each licensee shall establish a mechanism for recominending protective actions to appropriate state and local authorities ... in accordance with EPA PAGs. ;
J.9. Each state and local organization shall establish a capability for implementing protective measures,
... consistent with the recommendation of the EPA.
J.10.e. Provisions for the use of radioprotective drugs, particularly ,
for emergency workers and institutional persons.
J.10 f. State and local organizations' plans should include the method by which decisions by the State Health Department for administering radioprotective drugs to the general population are made during an emergency and the predetermined conditions under which such drugs may be i used by offsite emergency workers.
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REGULATORY FRAMEWORK Protective Measures '
(Continued) \
O i REP Radioloeical Emergency Preoaredness Exercise Evaluation Methodoloey (September 1991)
OBJECTIVE 14 Implementation of Protective Actions - Use of KIfor Emergency Workers. Institutionalized Individuals, and the l General Public Criterion 1. KI is made available once a decision is made for emergency !
workers and institutionalized individuals. !
Criterion 2. Sufficient quantities of KI are made available for emergency workers, institutionalized individuals, and, if the State plan specifies, members of the general public.
e Criterion 3. Appropriate instructions are available for those advised to
. take KI.
Criterion 4. All activities described in the demonstration criteria for l h this objective are carried out in accordance with the plan unless deviations are provided for in the extent of play agreement.
REP Radioloeical Emergency Preoaredness Exercise Evaluation Methodoloey (September 1991)
OBJECTIVE 14 Implementation of Protective Actions - Use of KIfor Emergency Workers, Institutionalized Individuals, and the General Public Demonstrate the capabilities and resources to implemeM KI protective actions for emergency workers, institutionalized individuals, and, if the state plan specifies, the general public.
Points of Review &ORh 14.1 Document the use of KI by emergency workers, institutionalized individuals, and the general public. I J:\temptech\ general \apnjunel. doc 2
REGULATORY FRAMEWORK Protective Measures (Continued) 1 14.2 How was availability of KI confirmed? l 14.3 Was the available supply of KI within the expiration date? !
14.4 Were instructions prepared or available for dissemination via Emergency Broadcast System or other means of primary notification on use of KI by members of the general public?
14.5 Were instructions prepared or available on the use of KI by emergency workers?
14.6 Were instructions prepared or available on the use of KI by institutionalized individuals?
14.7 In the implementation of activities associated with this objective, did the organization follow its plans and procedures?
- O 14.8 specirr whether er net the fo11 ewing demenstretive criteria were successfully demonstrated during this exercise:
O 1. KI was made available .... ,
O 2. Sufficient quantities were available, if state plan specifies, to members of the general public.
O 3. Appropriate instructions were available.
Q 4. All activities were carried out in accordance to the plan.
f ,
6 J:\temptech\ general \apnj une t. doc 3
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NU(llAt (NitGY INSil1Ulf J
John F. Schm6tt. CHP WaEc%ME#
to cssavasT February 12,1996 Mr. John C. Hoyle Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION: Docketing and Services Branch
SUBJECT:
Petition for Rulemaking Filed by Mr. Peter G. Crane (60 Egd. Egg. 58256 - November 27,1995)
Reauest for Comments
Dear Mr. Hoyle:
c The Nuclear Energy Institute (NEI)2 submits these comments on behalf of the nuclear energy industry. We have reviewed the proposed petition to amend the emergency plannmg standard in 10 CFR 50.47, (60 Eed. Egg. 58256 - November 27, ,
1995), " Peter G. Crane, Receipt of Petition for Rulemaking." The proposed petition recommends that the planning standard for protective actions for the general public include the prophylactic use of potassium iodide (KI).
The industry strongly urges the NRC to deny the petition and believes that l
including as a protective action stockpiling or predistribution of potassium iodide j will not add any significant public health and safety benefit to the adequate level j of protection currently provided by existing emergency planning at and around commercial nuclear power plants.
The NRC decided in September 1990 to reconsider the existing federal policy on use ,
of potassium iodide. The NRC's decision was prompted by a request for the establishment of a national stockpile program by the American Thyroid Association I
1 NEI is the organtastion responsible for estabhahing unified nuclear industry pohey on matters affecting the nuclear energy industry, including regulatory aspects of genenc operauonal and technacalissues. NEra members include all utthties bcensed to operate commercial nuclear power plants in the United states, nuclear plant designers. major architect /engineenne Arme, fuel fabncation facihtsee, matenals beensees, and other organisations and andmduals involved I in the nuclear energy assue. These comments also reDect technicalinput and support from the Electne Power Research Instatute, )
j
%)
I I
i 1
<. Mr. John C. Hoyle 4
February 12,1996 o . Page 2 in September 1989. The determinations made by the Commission in May 1994, the a
information provided in the industry's white paper submitted in December 1993
- during the reconsideration, and the conclusions reached by the subcommittee of the j inter agency Federal Radiological Preparedness Coordinating Committee in September 1995, remain valid and provide the bases to reject this petition to change the regulations.
- Potassium iodide can be affective in protecting the thyroid gland from radiation l dose due to inhaled radioactive iodine during an accident. It accomplishes this by ,
! " blocking" the thyroid with a large amount of stable (nonradioactive) iodine, but the 1 pills must be taken shortly before or within several hours after the exposure to the ,
- radioactive iodine. Any large release, which is highly improbable, from a nuclear power plant would also include other radioactive elements for which KI would not offer protection. Risk due to thyroid dose is of significantly less concern relative to the risk associated with external radiation from noble gases.
. The current Federal Policy on Distribution of Potassium Iodide for Use as Thyroidal ,
, Blocking Agent provides sufficient guidance to state and local governments that, l within the limits of their authority, should consider FRPCC recommendations in !
the development of emergency plans in determining appropriate actions to protect
- 0 the general public.
NEI (then NUMARC) provided a white paper to the Commissioners on December 7, L 1993, stating why the industry had concluded that " stockpiling or predistribution of
- potassium iodide (for the general public) will not add any significant public health
- and safety benefit to the adequate level of protection currently provided by existing emergency preparedness at and around commercial nuclear power plants." The F paper discussed the lessons learned from events and studies - such as the '
Chernobyl accident and the NRC analysis report, advances in source term ,
knowledge, continuing experience with a state KI distribution program, and the 1993 NRC report on KI - that occurred since the original 1985 federal policy. The white paper also quoted EPA's 1992 Protective Action Guides which states that although the use of KI has been identified as an effective protective action,
" evacuation and sheltering are, however, preferred alternatives for most situations because they provide protection for the whole body and avoid risk of misapplication !
of potassium iodide." All of this makes a strong case for maintaining the current i policy, and associated regulation, which does not recommend that predistribution or stockpiling be required for the general public. Enclosed is a copy of the revised j white paper which we feel adequately addresses the pe'titioner's concerns and i strongly urges the NRC to retain its current policy. The only revision to the '
.. .. ' original paper is deletion of discussion of the American Thyroid Association and Dr. I
, Q Becker's views. These views are otherwise available to the NRC.
. Mr. John C. Hoyle February 12,1996 Page 3 -
O Since the adustry review and submittal, two additional reviews have taken place i
3 which support retaining the current KI policy. On May 6,1994, the NRC Commissioners voted to retain the current policy, and the Federal Radiological ,
Preparedness and Coordinating Committee (FRPCC) Subcommittee on Potassium 4
l Iodide Report and Recommendations, submitted to the FRPCC Chairman on 1 September 15,1995, recommending that the current policy should not be changed.
The NRC staff provided four options to the Commission in the Addendum to i SECY-93 318, dated March 24,1994. They were: (1) make no change to existing NRC policy; (2) await a request from the federalinteragency committee which recommends federal policy on these matters before changing the NRC policy; (3) adopt a change in NRC policy which would encourage federal authorities to ,
purchase KI reserves; or (4) have NRC, in coordination with Health and Human Services and FEMA, revise current federal policy to make KI available to the states.
This last option is the one recommended by the staff.
NRC Commissioner de Planque's comments on SECY 93 318 and SECY 94-87 supporting the May 6,1994, vote to retain the current policy discussed the current ;
O policy discussed the current policy, stating "The federal KI policy was formulated in 1985 by the Federal Radiological Preparedness Coordinating Committee, an organization in which about 15 federal agencies participate. (Sep_50 Eg.d Egg.
30258-30259 (1985)) The policy is aimed at providing guidance to state and local agencies responsible for radiological emergency planning. In brief, the policy l recommends the stockpiling or distribution of KI during emergencies for emergency 1 workers and institutional persons, but does not recommend predistribution or !
i stockpiling be required for the general public. The policy neither bars nor encourages State and local authorities choosing to make KI available on a site-specific basis." ,
I Commissioner de Planque's comments also noted that even with the staffs reevaluation it does not suggest a change should be made in the current policy, "In !
fact, I find that the new analyses further support the 1985 policy from the point of l view of both cost / benefit and extremely low probability of the usefulness of a KI program (either stockpile or predistribution), given the situation in the United States. Rather, states and local authorities should be left completely free to determine whether stockpiling or predistribution makes sense in the context of a
. particular site. Their decision should be based on their own assessments of risk and benefit and other pertinent factors." The industry fully agrees with this view, l
O l
.. Mr. John C. Hoyle February 12,1996 Page 4 The Commission vote (first publicly available on May 20,1994) is transmitted in a Staff Requirements Memorandum dated May 6,1994 states, "in the absence of a clear-cut regulatory justification and because the Commission was unable to agree to change the policy, the current Federal policy on the use of KI remains in effect."
The Commission continues to agree with the original policy document statement -
that a " nationwide requirement for the predistribution or stockpiling for use by the general public would not be worthwhile." These determinations regarding the previous decision to retain the current policy remain valid to support the case to deny the current petition for rule making.
In 1991, the FRPCC established an Ad Hoc Subcommittee on Potassium Iodide to reexamine the 1985 policy and to consider the federal government purchasing and stockpiling KI for use by the public. The subcommittee conferred with the Conference of Radiation Control Program Directors, evaluated state policies on KI, current needs, invited and solicited input from states concerning use and distribution of KI to the public, evaluated foreign experiences, and the updated NRC study on the cost effectiveness of stockpiling KI for the public. The FRPCC subcommittee submitted its recommendations to the Chairman of the FRPCC on September 15,1994. In the body of the report the subcommittee notes that, "In conducting its reviews of the post-1985 data, the Subcommittee on KI uncovered no O new information that changes the bases for the 1985 recommendations concerning public use of KI." As part of the Subcommittee's review, FEMA conducted a survey of states that would be affected by a change in the current KI policy. The survey revealed that 33 of the 43 responding states were opposed to the creation of a KI stockpile program. The report notes, "The problems involved in distributing KI to the general public and the states' uae of evacuation as the primary protective action were the major factors that these states cited in not supporting such a Federal initiative."
The subcommittee report concludes with the following recommendations: the FRPCC policy on KI (Federal Register Vol. 50, No.142 - Wednesday, July 24,1985)
- should not be changed, and the federal government should not stockpile KI for use i by the public. This report was forward to Mr. Dennis H. Kwiatkowski, Chairman of i the FRPCC, on September 15,1994.
4 The availability of KI for the general public will not add any significant public health and safety benefit to the adequate level of protection currently provided by existing emergency preparedness ut and around commercial nuclear power plants.
Consideration of the realities regarding potential release of radionuclides and the
- practicality ofimplementing an affective potassium iodide distribution program lead to the conclusion of no significant additional benefit.
O
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Mr. John C. Hoyle February 12,1996 Page 5 - ,
73 O
l In conclusion, the events that have occurred and studies initiated since the 1985 l federal policy make a strong case for maintaining the current policy. Current i
guidance is available to state and local governments that wish to make KI available '
to the general population if they feelit is appropriate. Given the safety record of the U.S. commercial nuclear power program and demonstrated strength ofits current emergency preparedness programs, the industry strongly urges the NRC to deny the proposed petition and to retain the current policy as providing adequate protection of public health and safety.
We appreciate the opportunity to comment on the Petition for Rulemaking filed by Mr. Peter G. Crane. If you would like to discuss our comments further, please do not hesitate to call Alan Nelson at (202) 739-8110 or me at (202) 739 8108.
Sincerely, CLY- (
'ohn F. Schmitt JFS/APN/hmm O sucies re p.
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ENCI.0SUBE NUCLEAR MANAGEMENT AND RESOURCES COUNCll 1776 EW Street. NW . Sute 300 . wasnington. DC 20006-3706 (202) 872-1280 amo r.cown
! $ ".eu 'ce s December 7,1993 E
4 ne Honorable Ivan Selin Chairman .
U.S. Nuclear Regn1=wy Commission Wa<hiaran. DC 20555 Dear N. ChakHnan*
L ne Nuclear Regulatory Commission announced in the Federal Register (55 Fed. Reg. 39768) on September 28,1990, that it is reconsidering the federal policy issued in July 1985 on distribution and use of pc*msium iodide (KI) durmg an cmergency. He present federal policy is that predistribution or stockpiling of KI for use h '
by the general public shall not be required. We understand the Commission is presently considering input from the staff on this subject contained in SECY-93-318, " Reevaluation of Policy Regarding Use of Potassium Iodide After a Severe Accident at a Nuclear Power Plant."
We completed a review of events that have occurred since July 1985 that may
- furycit chaapag the present policy. He results of that review are provided irrthe enclosed white paper, " Review of Federal Policy on Use of Potassium Iodide."
The industry believes that the stockpiling or predistribution of potassium iodide will not add any significant public health and safety bene 6t to the adequate level of protection currently provided by existing emergency preparedness at and around
< c+-- -shi nuclear power plants. Events that have occurred and studies initiated since the 1985 federal policy make a strong case for maintaming the current policy. In addition to the substantial costi a=em to our industry that we believe are unjustifiable,
- Wilias or predi.hhtion and the associated public education would result in a potentially significant negative public perception. De industry strongly urges NRC to retain its current policy as providing adequate protection of public health and safety.
o .
- - - . - - - - - - - . - , - , .- - .,-.,..,n. , - - . . , , ,,
'Ihe Honorable Ivan Selin December 7,_1993 g
Page 2 l
If the Commission has any questions regarding the enclosed white paper, please call me or Tom Tipton.
Sincerely,
, r<Ahl '
j F. Colvin JFCHET: pig i Enclosure l l
c: Commissioner Kenneth C. Rogers Commissioner Forrest J. Remick ;
Commissioner Gail De Planque a W
Jan4es M. Taylor, Executive Director of Operations am 9
4 9 ;
l
o pi REVIEW OF FEDERAL POLICY l I
ON l l
USE OF POTASSIIIVIIODIDE DECEMBER 1995 (REV.1)
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, Nuclear Energy Institute Suite 400 1776 I Street, N.W. '
Washington, D.C. 20006
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. i INDUSTRY WHITE PAPER Q
I BEVIEW'OF FEDERAL POLICY ON USE OF POTASSIUM IODIDE j -
INTRODUCTION i ' On September 28,1990, the Nuclear Regulatory Commission (NRC) announced in the Fedemi Register (55 Fed. Reg. 39768) that it is reconsidering the federal policy on the disnibution and use of potassium iodide (KI) during an emergency. The purpose of n this industry white paper, " Review of Federal Policy on Use of Potassium Iodide," is to ,
discuss technical and historical pm.ymives pertinent to reconsideration of the policy for stockpiling and public use of potassium iodide for hypothesized nuclear power reactor accidents. Study of these issues clearly demonstrates that stockpiling and public use of potassium iodide will not add any significant public health and safety benefit to the adequate level of protection currently provided by plant safe operations and on-site and off-site emmgf preparedness activities. The industry strongly urges NRC to close ,
. reconsideration of this issue and to retam the current policy.
! FsnERAL POLICY CONSIDERATIONS
- O j ne use and application of potassium iodide as a thyroid blocking agent in a radiation emergency has been debated for at least 15 years. On dew 15,1978, the j Food and Drug Administration (FDA) issued a notice in the Fedemi Register (43 Fed.
i Reg. 58798) announcing its conclusion that potassium iodide was safe and effective for
[ use as a thyroid blocking agent in a radiation emergency under certain specified
- conditions. He final recommendations noted that uncertainties still exist about its use and side effects. He FDA noticed the availability of potassium iodide in its fmal j recommendation and stated that "[ejach state is responsible for formulatmg guidance on l when, if at all, the public should be supplied with potassium iodide along with instructions on how to use it." FDA also emphasized that "[t]hese final recommendations
, on potassium iodide use must be seen in the context of radiation emergency p1===iag as a whole. ne us: of potassium iodide in radiation emergencies is not a panacea." ne NRC's "RW=+ary Impact of Nuclear Reactor Accident Source Term Assumptions,"
NUREG-0771 June 1981, su r yo&d the FDA's position and recommended that 4==ie .
be placed on other, more comprehensive emergency protection measures.
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NUREG/CR-1433, " Nuclear Regulatory Commission, Frannraation of the Use of i
! Potassium Iodide (KI) As An Emergency Protective Measure for Nuclear Reactor l Accidents," March 1980, prepared by Sandia National Laboratories for the NRC, stated
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that based on cost effectiveness the use of potassium iodide was not worthwhile. This ' ,
report also emphasized that potassium iodide was not a panacea and that its be balanced =ga% the cost and effectiveness of other protective measures such as l t
sheltering and evacuation. )
i The Federal Emergency Management Agency (FEMA) and the NRC have been l J
considering stockpiling potassium iodide since 1981. Richard Krimmt of FEMA testified on the issue before Senator Simpson's Subcommittee on Nuclear Regulation in April 1981, and again before Representative Markey's Subcommittee on Oversight and lavestigations in March 1982. At both hearmgs FEMA was supportive of the use of potassium iodide for the general public in an emergency, but recognized that its use should be ev=1a=*ad by each state or localjurisdiction and that specific plans for distribution, =dminietrative and medical assistance would be needed by these goverriments if potassium iodide were to be effective.
FEMA published a notice ofissuance of Federal Policy, " Federal Policy on ,
Distribution of Potassium lodide Around Nuclear Power Sites for Use as a Thyroidal Blocking Agent," (50 Fed. Reg. 30258, July 24,1985). The guidance provides justification for the use of potassium iodide for emergency workers and institutionalized individuals and stated that, "[t]he Federal position with regard to the predistribution or stockpiling of potassium iodide for use by the general public is that it should not be reqmred." He Federal Regrster notice also identified issues regarding stockpiling and g distribution that remmin pertinent today, "[a]ny decision by state and local authorities to use KI should be based on the conditions and site environment for the specific op.iisg
' commercial nuclear power plant and should include detailed plans for distribution, administration, and medical assistance."
ne NRC announced that it is reconsidenng the current federal policy on.the distribution of KI (55 Fed. Reg. 39768, September 28,1990) based on a request by the American Thyroid Association in September 1989 for the establich= ant of a national stockpile program. The NRC stated in the Federal Register notice that it believes that the 4
cost / benefit ratio supporting the current policy may have narrowed, based on experience dming the Chernobyl accident, and a reduction in the cost and increase in the shelf-life of potassiumiodide.
As part ofits reconsideration, the NRC released a study in June 1993, "An !
Analysis of Potassium lodide (KI) Phrophylaxis for the General Public in the Event of a l l
i Assamant Associate Direacr. Omcc of Nanual and The! Hazards. Federal h.-i l P . " Assacy, "Potassam lodide SWili= " AIF CCa October 6.1981. g) 2-i
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.. I Nuclear AMd-a'" April 1992.2 in Chapter 7,"The Applicability of KI Cost-Benefit 4
Ratios to Policy Decision" the analysis docmnent states "[t]he unencumbered and direct l
O application of the denved cost-benefit ratios for KI in a policy decision can in fact be l
justified only under the following two conditions." A valid policy decision must (1) l weigh the potential impact of model uncertainties and (2) the pmphylactic use of KI in l
the context of other protective measures. The report goes on to state that, "these two '
conditions do not exist." The report concludes by stanng "Although these cost-benefit ratios as credible and objective as current data allow, caution must be exercised in using :
[ these values in a policy decision."
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l CHERNOpYLIMPLICATIONS The NRC's NUREG-1251, Final Report, Vol.1, April 1989, " Implications of the Accident at Chernobyl for Safety Regulation of Commercial Nuclear Power Plants in the United States," Chapter 4, " Emergency Planning," reviewed facts about the Chemobyl i
eM4 : and their impact on emergency planning and preparedness around U.S.
mannn cial nuclear power plants. It addressed the contrasts in emergency plannmg, l noting the raore advanced levels of emergency planning and response capabilities around i U.S. plants. It also discussed specifies of the releases unique to the RBMK design, !
j noting that radioactive material potentially released would be considerably less for U.S.
plants because they have substantial containments. Chapter 4 also stated that, "[a]!though
!- low-probability, fast-moving accident sequences are possible, severe accidents at U.S.
plants would, in general, pmgress more slowly, resulting in longer times before release."
This allows for employing sheltering or immediate evacuation as a more prudent protective action.
'Ihe " Conclusion and Recommendations" portion (Section 4.2.4) of NUREG-1251, states that the use of potassium iodid.t for the Chernobyl incident does not alter the U.S.
gmm ds policy on rMi.uibuting or st~+niling KI for use by the general public; it should not be i%.imi.
NUREG 1251, Section 4.2 " Medical Services," reev= mined the use of potassium iodide for the public around U.S. nuclear power facilities based on the Chernobyl ,
experience. Section 4.2.3 " Assessment" states, "[fjor members of the general pubhe, l however, these conditions (exposure to release over an extended period] generally are not applicable, because evacuation is generally feasible and, when carried out, is more ,
I e5ective in dose reduction than administration of KI, since it can reduce the dose for all i
2 S. Cohse & A ===neen lac. Contract No. NRC 04-90 o70, prepared for U.S. Nuclear Regulaury ensum mmum Reemor and Plant Safety issues Branch. Divmon of Safety issue Panaamn ogiae of Nacisar Regulaansy Research O !
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body organs and not merely the thyroid gland. Because of these considerrions, the policy statement concludes that a nationwide requirement for the predistribution or g
' st-Imiling for use by the general public would not be worthwhile. It further concludes thtt the decision' to use KI should be made by the States and, if appropriate, by local authorities on a site-specific basis.... He apparently successful use of KI at Pripyat does not alter the validity of guidance that recognizes that evacuation of the general public in the affected area could result in a greater overall dose reduction.,
The NRC's most recent report 2also reviewed the Chernobyl experience and in Appendix E, "KI Experience in Past Nu: lear Emergencies" it concluded that while KI was distributed to the public, "... the bulk ofiodide prophylaxis was restricted to the avoidance of thyroid burdens from the ingestion of cond=d food products." The report recognizes that use of KI to counter some effects due to people eating contaminated food was more necessary at Chemobyl than would be the case in the U.S.
due to differences in food distribution systems. The report states, "[f]or U.S. populations, there is a lack of dependency c's localized food products in the event of a nuclear emergency which therefore, limits the value ofiodide prophylaxis to plume inh =i= don of ;
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radioiodine." With the less lor =li~d food disuibution situation in the U.S., food I interdiction is more possible, and indeed is preplanned and periodically exercised. As with evacuation, interdiction is prefe.rable to use of potassium iodide because it provides evisction for the whole body.
4 The report also recognized additional circumstances that could decrease the value
- of public use of potassium iodide in the U.S. in comparison to the Chernobyl setting.
Theseinclude:
' . Design of the RBMK vs. typical U.S. LWR - specifically the accident scenario including release fraction, release rate, duration of release, j
(Section 7.1.1 " Reactor Accident frequencies" states, "the values of reactor sWt frequencies used in this report must be regarded as the single most significant uncertainty affecting the cost-bene 5t ratio...");
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. Honeng densiths in the Soviet Union "[p]opulation densities affected by nmitifamily residents in the Soviet Union have a profound affect on distribution procedures, methods, and distribution efficiency"; and i . " Dietary intake ofiodine. A low dietary intake ofiodine (is common among European counuies; the opposite dietary situation applies in the 3AnA=L_afTa-. . IN (KD Fu.Y,h for & C ---M 7.Ilh h of a N A-AnddenL Aped 1992.
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U.S.)' increases the thyroid uptake and thyroid dose for a given exposure j
Q condition. The prop *afl actic benefit of stable iodide is, therefore, =!=md by low dietary im=kas."
l The fact that potassium iodide distribution is fairly common pracuce m Europe is '
not a valid reason for chanain: the current policy in the United States (U.S.). There are signi6 cant differences in the level of U.S. and European emergency preparedness (e.g.,
organization, training, facilities, equipment, and regulatory oversight) that need to be considered in evaluating the relative additional benefit of potassium iodide within the U.S. programs which stress rapid capability for notification and evacuation if needed.
Study ofiodine prophylaxis associated with the Chernobyl accident highligh" these and l
significant societal differences. Review of Chernobyl indicates potassium iodide would l be ofless benefit in the U.S. due to the additional protective features of our pwpbcas j l Programs.
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l SOURCE TERM WORK I
! A c-- ; = hon of the 1975 WASH-1400 results (the current basis for the federal policy) with NUREG-1150, " Severe Accident Risks: An Assessment for Five U.S. i 1 Nuclear Power Plants," October 1990, shows that the accident frequencies and source
> terms were otiginally overstated by one to two orders of magnitude. Draft NUREG- l 1465, " Accident Source Terms for Light-Water Nuclear Power Plants," June 1992, notes !
the differences compared with WASH-1400 in the chemical transport ofiodine; thus the iodine available for release to the environment is also lower. These advancements in A- - Aia of accident source term argue against source term as ajustification for l l '
ek==* to the current federal policy on Kl.
EPA PROTECTIVE ACTION GUIDELINES l i l The Environmental Pmtection Agency (EPA) issued its final guidance on l l
r ctive action smidaliaes, " Manual of Protective Action Guides and Protective Actions for Nuclear Accidents," EPA 400-R-92-001, May 1992. EPA reviewed the use and application of potassium iodide in Appendix C, "Pmtective Action Guides for the Early ;
1 Phase: Supporting Information," Section C.2.3, " Thyroid Bl~+ing " EPA agreed with i FDA that use of potassium iodide has been identified as an effective pmtective action, but noted, "[e]v don and sheltering are, however, paforied alternatives for most situations because they provide protection for the whole body and avoid the risk of misapplication of potassium iodide."
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INDUSTRY EXPERIENCE g As a result of the Three Mile Island accident, the State of Tenne.ssee decided to predistribute K1 to residents within a five mile mdius of the nuclear power station.
Appendix E of the NRC's report
- describes, "He Tennessee Experience," and its
" Program Effectiveness." In 1981, KI was distributed to 66 percent (3022) of the total households (5591) at an esnmated cost of S125,000.
In the fall of 1984, three years after the initial door-to-door predistribution, residents were contacted that a new supply of KI was available for pick-up at identified region centers. Thirty-two pa of the eligible households responded. Based on recent di=o=* ions with TVA, it is our understanding that less than five percent of the households retrieved their replacement KI in 1992. The Tennessee state officials had considered the pilot program a success, but based on the volunteer retrieval rate dropping from 66 percent to less than 5 percent, the program's continued validity is questionable.
Another issue revealed as a result of this experience vas that the thousands of vials no longer useful due to shelflife expiration are now considered hazardous waste, thus adding additional cost and =dmini<trative burdens not previously considered.
He lessons learned from the Tennessee experience regarding the adminictration and cost of either stockpiling or predistribution of KI should be considered in the a W
reevaluation ofthe current policy. ,
OTuncu PAPERS ON THE ISSUE At the Atomic Industrial Forum Conference, " Radiation Issues for the Nuclear
!ada="y " OGuber 3-6,1982, a special session was held regarding "Use of Potassium Iodide in E%2y Planmng for Nuclear Power Plants." Dr. Bernard Shleien from the i Bureau of Radiological Health of FDA (FDA Project Manager, " Potassium Iodide as a l nyroid Blocking Agent in a Radiation Emergency: F' m al Recommendation on Use" 47 Fed. Reg. 28158, June 29,1982), who dispositioned public comments to the Federal Regirter notice re s ding final recommendations on use of potassium iodide spoke during i this session. Dr. Shleien stated in his presentation, " Issues Conceming the Use of i Potassium Iodide as a Thyroid-Blocking Agent in a Radiation Accident," that several wuversial issues regarding potassium iodide were unresolved. These include:
- An A=%e. of the P _= .T. ImuA (Kn p_;. :.xis for the Gm. .el Public in the Event of a NA M Apni1992.
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4 . Is the probability of a nuclear power plant accident r==1 ting in a hazardous release ofiodine so small that eth' consideration of the admini<tration of KI O- to ibe,ubiicis unnecessarx2
! . Is stockpiling and distribution of KI feasible and cost effecove? =
t . What other pes.Gve actions are possible and does their employment i negate the need forusing KI?
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While these questior.s can likely never be answered with cmsay, the information 0 4 in the past 11 years point to less, not more, potential benefit and workability of KI usein emergency situations.
i Dr. Becker and the American Thyroid Association have published views on this issue. We refer the reader to their positions.
l IFfDFSTRYPERSPECTTVES L
In this section of this paperwe provide the nuclear power indaa y's p .y -w i
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l In May 1982, the Atomic Industnal Forum issued, "Stanenient un the Use of Potassire lodide By the Atomic Industrial Forum Comminee on Environment." In its ,
p u..- ==4*iaac" the statement said "[wje believe that pre-distribution to individual l members of the public is inadvisable" because, among other reasons, "[t]here may be a
! false sense of m, k given f to the recipients of KI from a perception that its use would also reduce the radiation dose to other criti~1 body organa, e.g., bone marrow, lung, etc."
- Additionally, "[t]he pre-distribution of KI and the maimenance of an adequate supply j among individual members of the population have numerous =dminierative and logistic problems...[t=5 '
- t] possible utilinnan at the wrong time, loss of the KI by l
! individuals, and overuse of KI in the belief that larger doses are ber@i=1 "
l _ The purt.hase cost and implementation of a policy supporting potassium iodide stockpiling or predistribution to the public would add suba=nti=1 costs to utilities -
rasepayers. These costs would be r~1imi both shMy due to utilities modifying l emergency plans and regsod public information ==W=1= to address these added l rm cdve actions, and indhe dy through NRC and FEMA use fees billed for I devek-- - --- . . . ". . -.. . . , and exercise of the stockpile and distribunng system, as well
- as FEMA review of madified state and local emergency plans and procedures. !
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Due to the shelflife of KI, a full replacement and distribution weuld need to take .
place through the remainitig opummg license of the facility. The program also needs to be maintained for transient populations as well as resident unnover. Based on the cmrent age of the U.S. nuclearindustry we might expect that this would occur two to three more times during the license life of the facilities, resulting in substantial cost across the indusuy. I In the past KI has been a high profile issue of great public interest. It is reasonable to expect high levels of media and public interest associated with any change in federsi policy on this issue and the associated public education. Members of the put,lic will wam i
to know if the federal policy is being changed because the plants are less safe. Public caa6d-e in the technology could be affected by the decision.
It is ocr smoermnding that one of the reasons given to predistribute KI is public opinion and caand-a reyudisg the safety of nuclear power in this coumry. Quite to the contrary, surveys taken by Buskin /Goldering Associates 5 indicatad more favorable public opinion after the Chernobyl accident. "'Ihe peruentages of Americans who rated nuclear enerEy Pl ants " unsafe" dmpped from 48 percent just before the accident to 34 percentjust ana..id (February 1986 vs. May 1986)." This was confirmed by surveys done for the Ne'ianal Science Foundation. It was doc --- +i that four months prior to the event Americans thought that the benefits of nuclear power outweighed the risks by 51 pow to 40 percent. One month after the scaidant it was 56 nercem to 38 percent.
The survey also stated, " Americans now give higher safety ratuqp for nuclear energy plants than they did a dae=da ago. Only 27 percent rated them imafe in May 1993 g
E-- ; - od with 48 percent in February 1984." .
The nuclear power industry's emergency response capabilities (defense-in-depth) have mamred as a result of twemy-three years of emussocy ymy.edness experience,
> b@a-:ng in 1970 with the issuance of 10CFR50.34, embodying the first emergency preparedness rules. It has been thirteen years since implementation of 10CFR50, Appendix E, and NUREG-0654/ FEMA P.EP-1, Revision I, providing for substantial expansion of both onsite and offsite emergency preparedness progrmns. Over the past 13 years annual exercises and actual non-radiological events have tested the adequacy of these programs. 'Ihis has demonstrated an acceptable state of emergency pmpiuedness capable of adequately pws.: g the health and safety of the public.
s Paspecons on Pelic Opiamn. piepami by (JSCEA. "On Nodear Power Sainy,' My 1993.
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4 CONCLUSION h .
'Ibe predistribution or stockpiling of potassium iodide will not add any signifu-snt lh public health and safety benefit to the adequate level of protection currently provide exisung em .scy preparedness at and around commercia! nuclear power plants.
Consideration of the realities regarding potendal release ofradiciodines and of the practicality ofimplementmg an effecove potassium iodide distribution program lead this conclusion of no signi5 cant additional bene 5t. There would be substantial cost i=asm to our industry that we believe are unjusti5able, in addition to the potential
' negative public perception impact that predistribution or stockpiling and the associate public education would cause.
Taehaical practicalimplementation, cost / benefit and political considerations make potassium iodide predistnbution or stockpiling inappropriate. Events that have os and studies iaMead since the 1985 federal policy make a strong case for maintaming the dal nuclear power pmgram
> current policy. Given the safety record of the U.S. co and the da=c a-. =' strength ofits current emergency ps.gorsdness programs,-the isa sy stmngly urges NRC to retain the current policy as providing adequate p =d=- !
ofpublic heakh and safety.
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i STATEMENT OF ROY R. WIGHT
- i. C MANAGER, OFFICE OF NUCLEAR FACILITY SAFETY h DEPARTMENT OF NUCLEAR SAFETY
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. STATE OF ILLINOIS I BEFORE THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS i i l ROCKVILLE, MARYLAND )
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APRIL 4,1997 i POLICY ON ISSUANCE OF POTASSIUM IODIDE ]
i COINCIDENT WITH NUCLEAR POWER ACCIDENTS. i l
The State ofIllmois recogmzes the value of the prophylactic use of KI for thyroid
! blocking following a nuclear power plant accident,'and our radiological emergency i n.sponse plans include provision of KI to emergency workers and immobile populations !
in the affected areas. For protection of the general public, however, we agree with the prevadng Nuclear Regulatory Commission (NRC) position that, in almost all 4.
circumsances, evacuation is the most effective protective measure, especially when the !
decision to evacuate is based on plant status and is placed into effect prior to any release 1 of radioactive material to the environment. In-place sheltering should be considered only in those situations in which the potential risk to the public due to evacuation would be i-greater than the risk due to remaining in place; these include short-duration releases and
. extremely severe weather conditions that would make even short-distance vehicular l
, travel a life-threatening proposition. It is under such circumstances that some see the i public distribution of KI to be some benefit. We contend, however, that the same l conditions that would preclude evacuation would also preclude effective general !
7 distribution of KI in a timely manner (i.e., within several hours of exposure). We further believe that predistribution is not a viable option. Such a plan was put in place by the Tennessee Valley Authority and was a dismal failure. Greater public protection is achieved by maintaining the information networks and preparedness capability to decide upon, and implement, evacuation in a timely and orderly fashion. I The State ofIllinois, therefore, has adopted the above policy in concert with the existing policy of the Federal Radiological Preparedness Coordinating Committee's Ad Hoc Subcommittee on Potassium Iodide regarding steckpiling and distribution of KI.
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O su==^=v or ras inus =Ario*ite FOR ISSUANCE OF POTASSIUM IODIDE (KI) 4 It is the policy of the Illinois Department of Nuclear Safety (IDNS) to pre-position supplies of KI for use by emergency workers and immobile populations within the Emergency Planning Zones (EPZs) for commercial nuclear power plants. Pre-
, distribution and use of KI by the general population within nuclear plant EPZs is not supported. Use of KI during an emergency will be recommended by IDNS based on
- infonnation specific to the emergency situation, and its ingestion by affected individuals ;
- . is voluntary.
The ingestion of stable KI is designed to block the uptake of radioactive iodine by !
the thyroid gland should radioiodines be released during a nuclear plant accident. The U.S. Food and Drug Administration (FDA) recommends the taking of KI only if the i projected dose of such radioiodines to the thyroid equals or exceeds 25 rads.
IDNS believes that general distribuNon of KI is inconsistent with the agency's mission ta protect the health and safety of the public following a nuclear power plant O accident. Settin8 aside issees ofiesai resPensibiiities and iiabiiities. er of ecenemic and administrative burdens, IDNS believes the issuance of KI to the general public is 1
inadvisable for a number of reasons, principal among which is that offsite doses from a nuclear plant accident simply are not generally expected to exceed a few percent of the Federal action level of 25 rads. In fact, the American Thyroid Association has suggested that administration of KI is not warranted until projected thyroid doses exceed 100 rads -
four times the FDA action level. Although KI is a relatively benign drug, it does have side effects, and the larger the population base which ingests KI, the greater the risk of undesirable reactions. It is also recognized that although the thyroid performs a l
, necessary biological function, the loss of the thyroid gland is not life-threatening and can i j be overcome with appropriate medication. l l
i Because it protects only one organ against one of the numerous radioisotopes which can be released during a nuclear plant accident, KI cannot be regarded as a panacea for all radiation exposure. The State ofIllinois (and most other states) prefers a i more effective approach to potential radiation exposure, which is to maintain adequate information and notification networks and emergency response capability such that evacuation of an endangered population, when necessary, can be decided upon early and conducted in an orderly fashion. This concept, as embodied in the Illinois Plan for j
. Radiological Accidents (IPRA), can afford total protection from needless radiation 2
l exposure. Thus, the use of KI is best viewed as one aspect of a total personnel protection
" agenda, most appropriate for specific situations where exposure can be estimated and controlled, or where evacuation may be impractical, e.g., emergency workers and immobile, institutionalized populations. The risk of side effects for these individuals
- remains, but can be recognized and treated promptly. l l
l In short, the potential benefits of KI are outweighed by its limited effectiveness 1 and the risks its widespread administration would pose to the public. IDNS therefore joins the majority of states in recommending the issuance of KI only for emergency workers and immobile populations, for whom it can provide the greatest protection without undue risk. :
In the event of a nuclear power plant accident where it is determined under
! provisions of the IPRA that the projected or actual dose of radioiodines will exceed 25 1 rem to the thyroid ofindividuals who must remain within the EPZ of the plant by virtue of their immobility or the performance of emergency response activities, IDNS will
! recommend the voluntary ingestion of pre-distributed quantities of KI as follows: 130 mg per day for adults and 65 mg per day for children under the age of 12.
- It is assumed that immobilized populations such as mirsing home patients are l I
I under medical supervision and that adverse reactions or contraindicated usage can be
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centretied. emer8encv werkers receive sPeciiic trainin8 and instruction en the use ef xi.
Those emergency workers who decide not to comply voluntarily with the recommendation to ingest KI during an emergency condition may continue to perform their duties at their own risk or notify their supervisor that they wish to be reassigned. In either case, individuals must accept responsibility for their own decisions.
Members of the general public may ingest KI obtained from other sources at their own risk if they choose, or may seek medical advice from a physician regarding its use.
EPZ evacuees at state-supervised relocation centers, who may have been exposed by j virtue of delayed evacuation from an area impacted by a radiciodine release, will be 3~
referred to a hospital or physician for further evaluation if they request it or are found to be otherwise contaminated.
The process for making KI ingestion recommendations is contained in the IPRA and its accompanying Standard Operating Procedures. i 1
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Peter G. Crane / 4809 Drummond Avenue / Chesy Chase, MD 20815 / 301656 3998 March 26,1997 -
MEMORANDUM FOR: The Advisory Committee on Reactor Safeguards Peter Crane FROM:
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SUBJECT:
- POTASSIUM IODIDE (KI) 1
)' I very much ' appreciate the opportunity to present my views to the Committee.
. Because I have not seen the proposal that the NRC staff will be presenting to
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the Committee, I cannot comment on it, but will instead address the potassium
- iodide issue generally. Having dealt with the KI issue at length elsewhere, however, I intend to keep this memorandum short. I would ask the members of i
, the Committee to consider two attached documents, which I incorporate by ,
reference. The first is the petition for rulemaking that I filed with the Commission in September,1995. The second is a document prepared for a December 6,1996 meeting of the Maine Radiation Advisory Commission. -(My presentation to that commission was oral, and there was no necessity of i submitting the prepared text. )' ,
i The existing federal KI policy dates from the summer of 1985, nine months a
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betore Chernobyl. In October and November 1995, I wrote to James Lee Witt, Director of the Federal Emergency Management Agency, pointing out serious !
4 problems in the Federal Radiological Emergency Rerponse Plan, and enclosing a
- copy of my rulemaking petition. In response, Mr. Witt reconstituted the Ad
- Hoc Subcommittee on Potassium Iodide (which had been on the point of reaffirming the 1985 policy) and asked it to consider my rulemaking petition and j my letters to him. The result, confirmed unanimously by the full Federal Radiological Preparedness Coordinating Committee on October 24,1996, was, in the words of a FEMA official, a "new Federal policy of offering to fund a KI stockpile for those States who hereafter decide to include its use as a protective measure for the general public."' Almost five months after the FRPCC's W
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l ' At the December 6 meeting, the Maine Commission voted unanimously to
- recommend to the Governor that the State stockpile KI at the three reception centers in the vicinity of the Maine Yankee nuclear plant. The next day's
, Portland Press-Herald quoted one of the Commission's members, Donald Hoxie, a former head of Maine's health engineering division, as saying: " Ten years from ]
now, if we have a release, I would rather say that we [ erred] on the side of l conservatism, knowing what we know." The members of the Commission indicated at the meeting that they werc particularly impressed by the comments of Dr. Jacob Robbins of the National Institutes of Health, whose letter :
summarizing the arguments for KI I read aloud at the conclusion of my talk.
, ' Letter of March 5,1997, from Kay C. Goss, FEMA Associate Director for ,
. Preparedness, Training and Exercises, to Peter Crane. It appears as i Enclosure 3 to this paper.
i .-
O decision, however, the States and the public have yet to learn of the new policy, because no Federal Register notice has been published. According to the same FEMA official, this is because the NRC'and FEMA are " arranging the administrative details". to support the new policy.
. It might seem self-evident that when the Federal Government decides to abandon a policy that uses the phrase "not worthwhile" with regard to KI, in favor of a new policy of paying for state stockpiles, something has changed, presumably because something new has been learned. Nevertheless, even today, whenever the KI issue is debated, the defenders of the 1985 policy can be counted on to reptat the refrain that there is "no new data" impugning it.'
There are two problems with this claim. The first is that it is flatly, demonstrably untrue. For example, in 1%, when the Federal Government was formulating the existing policy, it was sdll possible for Shleien, Halperin et al.
of the Food and Drug Administration to write: "There is a paucity of human data relevant to the induction of radiation effects from iodine-131, particularly in children."' Sad to say, this is no longer the case; as the literature attests, Chernobyl has produced all too much new information on this subject.
Likewise, Shleien et al. reported disagreement on the safety of administering KI, mentioning in particular Yalow's predictions of adverse effects.' On this issue, there is now extensive probative data, documented in Nauman and Wolff's O paper on the Polish experience in administering 18 million doses of KI with minimal adverse reactions.
The second problem with the claim of "no new data" is that the existing policy was fatally defective from the start. Thus even if it were true that there is "no new data" today beyond what was available to the Government in 1985, this would be irrelevant: a policy change would still be appropriate, because the
- As I wrote to Director Witt in late December,1996: "The Subcommittee's recommendation was voted on by the full FRPCC on October 24, more than two months ago. Rightly or wrongly, a lobbyist for the nuclear industry has since proc 4 aimed a " win-win" for the industry position, and even asserted that no new technical information has developed since the existing KI policy was put in place in 1985. (In reality, the most signfiicant single data point is the epidemic of childhood thyroid cancer in the former Soviet Union, caused by the 1986 Chernobyl accident.) How can such claims be made? Because the public and the industry have yet to hear word one from FEMA about its resolution of the KI issue. "
- " Recommendations on the use of Potassium Iodide as a Thyroid-Blocking Agent in Radiation Accidents: An FDA Update," B. Shleien, J. Halperin, J.
Bilstad, P. Botstein, E. Dutra, at p. 5. This paper was before the Commission at the time that the current KI policy was being developed. It appears as
- Enclosure D to SECY-83-362 ( Aug. 30,1983).
' 14. at 2-3.
J I
e s. . .
O 1985 policy was based on a mischaracterization of the data then available.
- The flaws in the 1985 policy (which remains the current policy, while we continue to wait for FEMA's Federal Register notice) were plainly observable even before it was adop%i. : For example, the linchpin of the NRC staff's argument against KI in 1983, when the issue was presented to the Commission for decision, was that it was not cost-effective, when the rarity of severe accidents was factored in. However, the ACRS Subcommittee on Reactor Radiological Effects observed at the time:
The risk / benefit analyses conducted by the NRC Staff on this subject do not appear to be compatible with (or comparable to) approaches used in evaluating other aspects of nuclear emergency planning. For example, if the same evaluations were made, would there be any justification for the conduct of emergency drills or the installation of warning sirens?
- No satisfactory answer to the ACRS's comment was offered then or later.
A review of the record of what occurred on the KI issue between 1979 and 1983 suggests that the cost-benefit balancing that was used to disparage the value of O KI to the Commissioners in 1983, and that provided the rationale for the current U.S. policy on KI, was a post hoc rationalization for a decision already made on other grounds. The record includes the following:
-- In 1979, the President's Commission on the Accident at Three Mile Island (Kemeny Commission) criticizes the failure to stockpile KI, and recommends the creation of stockpiles; the NRC, later the same year, endorses the Kemeny recommendation and declares its ,
intention to make KI a licensing requirement. !
l
-- Between 1979 and 1982, the relevant federal agencies move forward I with plans for the implementation of the Kemeny recommendation.
-- In September,1982, the NRC staff submits a memorandum to the l Commission (SECY-82-396) asking it to approve an interagency !
policy statement (already approved formally or informally by FEMA, DOE, EPA, FDA, and USDA) which says, among other things, that "where shelter is used because the evacuation cannot be completed in time to avoid a substantial radiation insult, the administration of KI could be a useful ancillary protective action which could provide
' " Comments on the Use of Potassium Iodide (KI) as a Thyroid Blocking O Agent," April 30, 1983. It appears as Attachment 1 to Enclosure D of SECY-83-362.
a l
i l
t
~_ , r 4
E
>,e reduction to the thyroids of exposed
-some additional eN i individuals. "
l
-- In October,1982, the NRC staff, in SECY-82-396A, withdraws the !
, paper submitted just 18 days before. The new paper states:
{' I am now informed by our' Office of Research that in L
light of the information available on the behavior of f radioiodine during reactor accidents, a technical paper which could show that the use of po+ansfum iodide for ,
the ceneral public is sionificantly less cost benefir fal than previously assumed could be produced by January l 5
1, 1983. (The previous study sponsored by the Office '
of Research, NUREG/CR-1433, March 1980,- concluded ;
1 that the distribution of potassium iodide to the general :
e public was "only marginally cost-effective, 'at best.")
In view of this information, I am withdrawing the staff proposal contained in SECY-82-396. When the Office of Research paper is complete, I will send it to the other {
- Federal agencies involved with a recommendation that a policy statement recommendino acainst the stockpilino
'(
' and distribution of notassium iodide for the general public be developed.
The Commission should also be aware that FEMA has Igcently reversed its previous decision to purchase a laroe cuantity of notassium iodide for a national L
stockpile. [ Emphasis added.]
i Nothing in the October 1982 paper indicated that any new information on KI had been obtained during the preceding 21 weeks -- apart from the central fact that j
the Executive Branch had just reversed direction on KI, for reasons not stated in the paper -- yet it was already able to state what the cost-benefit analysis would find, and what the NRC's recommendation to the other federal agencies would be.
Before concluding, I note that the Committee will be hearing presentations from two gentlemen whom I had the pleasure of meeting last summer at FEMA, at the June 27,1996 meeting of the FRPCC Ad Hoc Subcommittee on Potassium Iodide:
i-Mr. Alan Nelson, of the Nuclear Energy Institute,and Mr. Roy Wight, of the
{
[ . Illinois Department of Nuclear Safety. At that time, both argued strenuously ]
against any change in the 1985 KI policy. I would like to address some of the l
. points they made at that meeting, on the assumption, perhaps not correct, that '
' their arguments to the Committee will be along the same lines as the views they expressed last summer. If in fact their views have changed since that time,
_) and I am addressing myself to positions they no longer hold, I apologize.
i l
O
~
The nub of my argument was that officials coping with radiological emergencies should have three tools at their disposal, to use singly or in combination as i particular circumstances might dictate or permit: evacuation, sheltering, and potassium iodide. The nub of Mr. Nelson's argument, as I understood it, was that potassium iodide is not needed. Seeking clarification of his position, I asked the following question:'
MR. CRANE: It is a question for Alan, which is: It seems to me, if ever we've got an event in which KI is needed, there are going to be a lot of people reading the transcript of this meeting. So I think it's good to be clear about one point. I understand what you're basically saying is, "We don't need this because evacuation works and evacuation is better." And what I would like to know is: Are you telling us on behalf of the industry that for every credible accident, complete evacuation of the affected population, apart from shut-ins and prisoners, is not only feasible but can be guaranteed?
MR. A. NELSON: I'm not sure it's my place to make that statement. The states and locals are prepared to implement plans based on recommendations and data that they have as precursors to events, precautionary measures that they take early on. It's not as simple as: Can you do these things as a guarantee of a lot of things?
As we have improved our emergency preparedness !
activities, emergency response data system is available, states are monitoring utilities, the NRC has their operations center and regional operation center to
- monitor the nuclear power plants. Safety systems have been improved, in spite of some of the points that were mentioned, where reactor operations and containment can be observed. Meteorological data, dose assessments are taking place at the same time.
Csnfirmation of protective actions early on may be implemented.
I think that we have improved our emergency plans to a point long after TMI. The same Kemeny position that was established back in 1979-1980, if evaluated today,
{A')
, , This is the verbatim transcript, pages 203-04, with only punctuation corrected.
/7 6 O
one would see that there has been a great deal of improvement in emergency preparedness.
I think that the adequacy of the public can be protected. And I think that the programs that we have seen in the state and local exercises and real events have borne that out.
I believe that this non-responsive answer, in which the word " evacuation" is not even mentioned, speaks volumes.
Mr. Wight, in his prepared statement to the June 1996 meeting, said:
It is also recognized that although the thyroid performs a necessary biological function, the loss of the thyroid gland is not life-threatening and can be overcome with appropriate medication.'
Before going any further, let me say that I am not impugning Mr. Wight's integrity or the sincerity of his desire to do what is right for the people of his state. I would suggest, however, that his statement at the June meeting, if I l understood it correctly, reflected incomplete knowledge about thyroid disease. !
The most recent projection of the American Cancer Society, as a telephone call will confirm, is that about 16,000 Americans will be dibgnosed with thyroid cancer in 1997, and about 1200 will die of it. Thus although the loss of the thyroid is not life-threatening in itself -- one can take medication to replace the hormone produced by the gland -- the cancer that causes the loss of the thyroid is fatal in a small but significant percentage of cases, and has serious impacts on the quality of life in a much larger percentage.
At the June 1996 meeting, Dr. Jacob Robbins, an eminent thyroid cancer specialist at NIH, had this to say when asked to comment on Mr. Wight's statement and on the actual consequences of the disease:
That is sort of hard to answer, but if you think of cancers in general, if you were going to have a cancer, it wouldn't be bad to have a thyroid cancer.
The mortality is low. And even in the children, whom we've heard have very aggressively growing thyroid
- Statement by Roy R. Wight, p. 2. Quite similar language appeared in the prepared statement of Sandra J. Threatt of the South Carolina Department of f Health and Environmental Control: "The thyroid performs a necessary (gb) biological function. However, loss of the thyroid gland is not life-threatening and can be medically managed." At p. 2.
l i A 7 cancers, the mortality is a few percent. 1 But we have to remember that the children that were l exposed who haven't had cancer yet are not free of thi ;
risk of getting cancer. So when they become adults, they can still get thyroid cancer. And then the risk gets higher, perhaps ten percent. We heard the number before.
So there is a risk of mortality. So for the individual who has the disease, mortality risk is low. It's treatable. But the treatment requires not only an immediate operation but lifetime surveillance, medication, the possibility that they will require radioactive iodine therapy repeatedly.
It's a significant medical illness. It's not a trivial illness. I think that's all that we need to say about it.'
Again, I do not mean this as an attack on Mr. Wight or the Government of Illinois. If today, any states are still under the impression that thyroid cancer is too trivial an illness to be worth preventing, that is less a reflection on them '
than it is on the Federal Government, which for some 15 years has failed to live up to its responsibility to provide the states with accurate and complete information on this subject." '
If there are any supporting documents that would be helpful to the Committee, I would be happy to supply them, as well as to answer any questions that the Committee may have. Thank you.
Enclosures:
A. Rulemaking petition (September 1995)
B. Statement to Maine Radiation Advisory Commission (December 1996)
C. Letter from Kay C. Goss, FEMA (March 1997)
' Transcript at 167-68.
O V
" See the April 20, 1994 letter to Chairman Selin from Senators Alan Simpson and Joseph Lieberman (attachment to the 1995 rulemaking petition).
. ,;r bM LO3 0/8t:- L.
l 1
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Petition of Peter G. Crane for ru1===kina to implement
~
the recorrendation of the President's C- insion on the Accident at Three Mile Island (Ke==nv Commission) that
[ the United States stockpile +hm drua notassium iodide for thyroid protection durina nuclear accidents i
I. Summarv The subject of this petition should be of nationwide .)
concern: the fact that the United States, unlike virtually all i 4
other countries in the developed world, does not stockpile the ,
drug potaselum iodide (KI) to prevent thyroid cancer and other '
thyroid diseases after nuclear accidents. KI preverts the i absorption of harmful radioactive iodine by saturating the thyroid gland with iodine in a harmless form. The drug is l extremely inaxpensive. In recommending stockpiling in 1994, the NRC technical staff estimated that a supply sufficient to protect the population nearest to all U.S. nuclear plants could be 4 established for a total of at most "a few hundred thousand I dollars," or ten cents per year for each person protected.
O Present U.S. policy, adopted in 1985 by an interagency policy statement, with NRC concurrence, holds that it is "not worthwhile" to require KI stockpiling. The policy reflects a
" cost-benefit analysis" which calculated that the drug was not I
, likely to pay for itself over time, and that it would be cheaper i in the long run to refrain from buying KI, and treat the i
- resulting thyroid disease, than use KI to prevent the disease, j l Looking only at dollar costs, the analysis did not take into l account what we all know intuitively
- that the worst part of !
illness is not necessarily the economic consequences.
l Currently, the federal government is sending confused and confusing messages both about whether KI is useful and whether it is available. In September, 1994, the Federal Emergency Management Agency issued a proposed Federal Radiological j Emergency Response Plan describing the duties of federal agencies during nuclear amargencies. The NRC, as the lead agency for accidents at nuclear power plants, is to advise state and local goveraments about " measures that they should take to avoid or reduce exposure of the public to radiation," including "amargency actions such as sheltering, evacuation, and crochvlactic use of i
iodine." In an amargency, an interagency panel will offer guidance to the NRC on when KI should be used. While the authors of the Plan plainly understand the drug's value in radiological emergencies, they seem not to realize that because of the 1985
( policy, all the elaborate procedures for making decisions about 4
..,% .,-wg, . -y... . , , _ . _ , . _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
..e ..
j 2
KI are pointless: in an emergency, there will be none to give
! 'out. l l
l The 1985 policy statement was the complete rejection of one j of the major recommendations of the President's Commission on the
~
Accident'at Three Mile Island (Kemeny Commission). During the TMI accident, state and federal officials looked for KI and l discovered that none was available. The drug had to be
- manufactured on short notice. The Kameny Commission'strongly criticized the failure to stockpile, and recommended that j regional stockpiles be established. Its report recognized that
- evacuation is not invariably the preferred response to an j amargency, and that even when evacuation is desirable, it may not i
be feasible. A KI stockpile means that amargency response officials have three arrows in their quiver: evacuation, sheltering, and iodine.
L i Initially, in 1979, the NRC warmly endorsed the Kameny j Commission's position on XI and announced that it intended to i make the availability of KI for the general public a necessary i part of every amargency response plan. As late as September 1982, all the responsible federal agencies were in agreement that KI stockpiling was desirable. A draft federal policy statement
- to that effect was circulated for agency approval. Only a few
- weeks later, for reasons.still unclear, FEMA and the NRC staff did a complete about face. FEMA cancelled its plans to purchase KI, the draft policy statament was withdrawn, and the NRC staff adopted a strongly negative stance toward KI.
i The NRC Commissioners' acceptance of the NRC staff's changed l position came after a November 1983 briefing in which staff j officials, none of whom is now with NRC, offered a seriously l inaccurate description of the nature of the disease that KI could l be expected to prevent. Never discussing cancers or fatalities, i the briefers advised the Commissioners and the audience that if a l member of the public was exposed to radioactive iodine during an l accident, the result could be a " nodule," easily ramoved, that
, would mean "a few days" of absence from work. The briefers did ,
j not mention that 40% of those radiation-caused nodules would be I cancerous, and that 5 to 10% of the cancers would be fatal. :
. The actual consequences of radiation-caused thyroid disease are far more serious than "a few days" away from work, as the
! recent news reports on the young victims of Chernobyl make grimly i clear. Though usually curable, thyroid cancer is lethal enough to kill 1,120 Americans each year, according to American Cancer i
- Society figures. Even when non-fatal, the disease and related I i
tests and treatment can severely affect the quality of life.
L 1
i.
J 3
In 1986, only a year after the policy statement was issued, the Chernobyl accident demonstrated how dangerously flawed the new U.S. policy was. In Poland, where the authorities moved
- vigorously to administer KI, 18 million doses were given out,.
with the result that 97% of all Polish children were protected and an upsurge of disease was avarted. In the then Soviet Union, on the other hand, too little KI was given out, too late.
Russia, Belarus, and Ukraine are now experiencing soaring rates of childhood thyroid cancer -- in some places, 200 times pre-accident levels -- and the worst may be yet to come.
U.S. policy did not change in response to the Chernobyl i
accident,.however, despite an urgent request from the American 1
Thyroid Association in 1989. In 1991, the World Health Organization declared that thyroid protection was " critical" during accidents, and said, " Stocks of iodine should be stored strategically at points including hospitals, schools, and fire and police stations." France, Germany, Belarus, Russia, l Switzerland, Austria, the Czech Republic, Japan, Britain, Sweden, i
Slovakia, and a host of other countries now protect their children with stockpiles of KI. They-follow the " International l Basic Safety Standards," issued by the International Atomic l ,
Energy Agency in 1994, which provide for giving out KI when projected doses exceed specified guidelines. The U.S. Government
, supported adoption of the Basic Safety Standards, which represent the consensus judgment of the world's radiation safety experts, but ignores them where KI is concerned.
d The current policy goes against the best judgment of the i NRC's own technical staff, which in 1994 declared, commendably, i
, that " prudence" called for KI stockpiling and recommended to the l
, NRC Commissioners that the U.S. Government buy the drug and make !
i it available to states at no cost. While the NRC staff's proposal for a change in policy was pending before the I i Commissioners, Senators Alan K. Simpson and Joseph I. Lieberman, I in an April 20, 1994 letter, urged the Commission to bring )
American policy on KI into line with the recommendations of I medical and scientific experts and international practice. They l
- also stressed the " moral responsibility" of the federal ;
^
government to be candid with the public about the risks of 3
federally-licensed activities anc ways of lessening those risks. l The only group to endorse the existing policy was an industry trade association, which urged among other things that stockpiling KI might make the public fear that nuclear plants ,
were unsafe. And so the lines were drawn: on the one side, the l Kameny Commission, the American Thyroid Association, the World Health Organization, the two Senators, the NRC's own technical l
4 l
i io staff, and the example of the rest of the developed world; on the other side, the industry trade association. When the Commissioners cast their votes, the outcome was a 2-2 tie. Under
]
NRC procedures, the deadlock meant that the NRC staff proposal failed. .The old discredited policy remains in place today.
- FEMA's 1994 Federal Radiological Emergency Response Plan
- takes the worst of all possible approaches, for it gives states
- and the public the illusion of KI protection without the reality.
The Government must choose: either to create stockpiles of KI, i
thereby making the Plan accurate, or revise the Plan and publicly explain that because of the existing federal policy, use of the '
j drug will not be an option in a nuclear amargency.
! This petition would resolve the dilemma by improving protection rather than correcting the Plan. It requests that the j Commission amend its rules (10 CFR Section 50.47(b)(10)) to l specify that the " range of protective actions" required to be set forth in State and local amargency plans includes sheltering, evacuation, and provision to administer KI, as envisioned by the j Federal Radiological' Emergency Response Plan. It asks the NRC to issue a policy statement explaining that KI is a sensible and
- prudent emergency planning measure, when used in conjunction with evacuation and sheltering, and declaring NRC support for federal funding of local and regional stockpiles. This approach would cost utilities nothing, and should not burden them in any way.
For a pittance, it could save thousands of Americans from thyroid
- cancer and other diseases if a major nuclear accident occurred.
[ KI may be compared to the lifejackets on a ferryboat:
- needed only rarely, but vital if the need does arise. We require j ferries to carry lifejackets not because we expect them to pay 4
for themselves over time, but because it is the reasonable and prudent thing to do. Likewise, we vaccinate our children against
, polio and diphtheria to prevent needless suffering and deaths, i not because we have calculated that this is a way to save money.
I
! The U.S. Government recently agreed to spend $15 million over 15 years studying radiation-related thyroid cancer in J Ukrainian children. This was sensible and appropriate. But can a rationci Government decide that it is worthwhile to spend $15 I million to study thyroid cancer in Ukrainian children, and not
! worthwhile to spend a fraction of that amount to crevent the same disease in American children? This petition says that it can't.
America's families deserve no less protection from radiation than l is provided to children and their parents throughout the rest of ,
the developed world. The NRC staff has pointed the way, and the Commission and the U.S. Government should follow. .
l
- _. . -- . - . --- - - - . .- - ~ - . __- - - . -- . -.
5 II. Factual Backaround 1
j_ A. Potassium iodide and its uses. l 1
Potassium iodide (KI) protects the thyroid gled -- which, especially in children, is highly sensitive to radiation -- from i the radioactive iodine that would be released in extremely )
} serious nuclear accidents. By saturating the gland with iodine i in a harmless form, potassium iodide prevents any inhaled or ingested radioactive iodine from lodging in the thyroid gland, where it could lead to thyroid cancer or other illnesses.
In addition to preventing deaths from thyroid cancer,' KI J prevents radiation-caused illnesses that although not fatal, can disrupt and even blight a person's life. Thyroid cancer, curable 4 in 90-95% of cases, generally means surgery, radiation treatment,
- and a lifetime on medication.' The changes of medication that go l
- with periodic scans put many patients on a physiological and 4
i s
- The American Cancer Society estimates the number of new cases in 1995 at 13,900, and the number of deaths at 1,120.
, Thyroid cancer represents about 1 percent of cancer cases i nationwide.
l See letter of Joseph E. Rall, M.D., Ph.D., Deputy Director for Intramural Research, National Institutes of Health, to Central Docket Section, Environmental Protection Agency, February 9,1990:
In the United States, there are approximately 10,000 new
- cases of thyroid cancer per year. Af ter initial surgical removal, ablation with I-131 is used to complete the
. thyroidectomy in in at least half of these patients (i.e.
l ~5000) in doses ranging from 30 to 150 sci. Most of
- these patients then receive one or more test doses of I-131 (2 to 10 mci) to detect the occurrence of metastases.
A conservative estimate of the number of patients who develop metastatic thyroid cancer who could benefit from I-131 therapy is 2000 cases per year. These patients receive from one to ten treatment doses of 150 to 300 aCi over a period of up te 20 years or more. This treatment is curative in some cases and prolongs disease-
, free survivial in many cases.
It should also be noted that unlike some cancers, which if they O have not recurred within a set period (such as five years) can be considered cured forever, monitored for life.
the thyroid cancer patient must be 4
m: -- __m
1 i
6-
' psychological rollercoaster.' - Hypothyroidism (an insufficiency.
i of thyroid hormone, which can result from radiation damage to the b ~ gland).can cause permanent retardation-in children and, if I
undiagnosed, can condemn adults to a lifetime of fatigue, weakness, and chills.' The drug has a long shelf life -- at least five years -- and causes negli.gible side effects.' '
B. U.S. coliev on KI nrior to the Three Mile Island accident.
j In December 1978, the Food and Drug Administration announced that it had determined that potassium iodide was safe and
{
j effective for thyroid protection in nuclear accidents. The issue attracted little attention, however, and the NRC and the Federal i Government as a whole took no public position on the drug.
Barely thraa months later, on March 28, 1979, the Three Mile Island accident began to unfold. After two days of unsuccessful efforts to bring the reactor under control, it was still uncertain whether a major release of radioactivity could be averted. Federal and state officials, searching for supplies of KI in case it should be needed, discovered that there was none to be had, in Pennsy3vania or elsewhere. A supply therefore had to l l t !
- Some years ago, for example, Senator John East of North
- Carolina incorrectly committed suicide because, according to his widow, an treated thyroid imbalance had made his life unendurable. President George Bush, after being treated with radioactive iodine for an overactive thyroid (Graves' disease),
i displayed symptoms characteristic of patients returning to thyroid hormone af ter the hypothyroidism caused by radiciodine treatments:
physical emotionalism. exhaustion, frequent talkativeness, and a tendency to The media may have missed the story (as President Bush's former press secretary observed in recently published memoirs),
what was goingbut at on.the time, old thyroid patients understood exactly as an* administrative As I had occasion to see when I was in the Marshall Islands judge with the Nuclear Claims Tribunal in 1991, many people who are chronically chilly and exhausted from hypothyroidism may be unaware that their problems are symptoms of
~
a treatable illness. As a result, they may never receive the drug (synthetic thyroid hormone) that would quickly relieve their !
symptoms and allow them to live a normal life.
- " Iodide Prophylaxis in Poland after the Chernobyl Reactor Accident: Benefits and Risks," Janusz Nauman, M.D., Ph.D.,
4-Wolff, M.D., Jan 524 (May, 1993). Ph.D., The American Journal of Medicine, Vol. 94, p.
l l
)
~ ,- ,,
be manufactured, literally overnight. At 3 a.m. on Saturday, March 31, a Food and Drug Administration official arranged with
_ the Mallinckrodt Chemical Company for the immediate production of 250,000 doses of KI. Without a written contract or a purchase order, the company began production (Parke-Davis soon followed suit), and the first shipment of the drug arrived in Pennsylvania
, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later.'
C. The President's Commission on the Three Mile Island accident recommends KI stockpilino.
After the accident, President Carter appointed John Kemeny, President of Dartmouth College, to head a commission to investigate the accident. Its report, issued in October, 1979, was strongly critical of the failure to stockpile KI. It said:
For over 25 years, the use of blocking agents such as potassium iodide to prevent the accumulation of radioiodine in the thyroid gland has been known. The effectiveness of potassium iodide administration for
! thyroid gland protection in the event of releases of radioiodine was recognized by the National Council on
,' ( Radiation Protection and Measurement in 1977. The Food and Drug Administration authorized use of potassium iodide as a thyroid-blocking agent for the general public in December 1978. However, at the time of the TMI accident, potassium iodide for this use was not commercially available in the United States in quantities sufficient for the population within a 20-mile radius of TMI.'
Among the Kemeny Commission's major recommendations was the following:
- " Report of the Office of Chief Counsel on Emergency Response to the President's Commission on the Accident at Three Mile Island," (October 1979), p. 91. See also Dr. Jerome Halperin,
" Potassium Iodide as a Thyroid Blocker --
Three Mile Island to Today," DICP, The Annals of Pharmr otherapy, Vol. 23 (May 1989),
which includes an insider's account of the effort to procure not only supplies of the drug, but also bottles, labels, and droppers, and get them to Pennsylvania.
Report of the President's Commission on the Accident at Three Mile Island, October 1979, at 41-42. With a single change -
'O -
from 25 years to 40 --
this would be also be an accurate statement of current preparedness to administer KI.
l.
4 r~ *
- Q) s An adequate supply of the radiation protective (thyroid blocking) agent,. potassium iodide for human use, should be available regionally for distribution to the general ropulation and workers affected by a radiological energency.'
21sewhere in its report, the Kameny Commission explained that different types of accidents, depending on their particular 4
circumstances, might require different kinds of emergency response:
A variety of possible accidents should be considered during siting, particularly " smaller" accidents which have a higher probability of occurring. For each such accident, one should calculate probable levels of i
radiation releases at a variety of distances to decide the kinds of protsetive action that are necessary and feasible. Such protective actions may range from i evacuation of an area near the plant, to the
! distribution of potassium iodide to protect the thyroid
' gland from radioactive iodine, to a simple instruction
' to people several miles from the plant to stay indoors
' for a specified period of time. ... Emergency plans .
l 2
must have built into them a variety of responses to a variety of possible kinds of accidents.'
The last point is particularly significant, because it shows l l
the Kameny Commission's recognition that in 193g accident situations, evacuation may not be the emergency planning measure
] of choice.
J D. The federal acencies back the Kamenv Cn==ission recommendation.
i Initially, the Kemeny Commission's recommendation in favor I
- of KI stockpiling seemed so obviously sensible as to be non-l controversial. In NUREG-0632, "NRC Views and Analysis of the Recommendations of the President's Commission on the Accident at j Three Mile Island," issued in November, 1979, the NRC declared
The President's Commission recommends that an adequate supply of potassium iodide be available for both workers and the general public. NRC agrees and is i
- Id. at 75.'
' 14. at 16-17.
1
-- ~
j ., ..
!O j
. planning to require licensees to have adequate supplies i
- of this agent available for nuclear power plant 4 - workers. For the general population, NRC expects to
~
include the availability of potassium iodide as a necessary part of an acceptable State emergency response plan. Plans have not been finalized as to i exactly how and to what extent the agent should be j stockpiled and distributed, but studies are underway to resolve this matter at an early date.
} For the next several years, the three agencies most
- concerned -- the Food and Drug Administration, responsible for
- approving drugs; NRC, expert in radiation protection; and the 4 Federal Emergency Management Agency, with responsibilities for amargencies generally -- were all on the same track, favoring the stockpiling of potassium iodide. In May 1982, however, the Atomic Industrial Forum, a nuclear industry trade association, declared itself against potassium iodide."
The NRC staff was strongly in favor of KI stockpiling as
! late as September 27, 1982, when it sent the Commissioners a memorandum numbered SECY-82-396 (" Development of a Federal Policy
, Statement on the Distribution and Use of Potassium Iodide for l i Thyroidal Blocking in the Event of a Nuclear Power Plant Accident"). In that paper, the staff proposed that the Commission agree with a draft interagency policy statement supporting KI stockpiling.
The draft policy statement is worth quoting at length, i because it describes with clarity and accuracy both the benefits of KI-and the limitations of the drug. It says:
l
....KI blocking only effectively reduces the radiation i
- exposure of the thyroid gland. While-this is an 4 important contribution to the health and safety of the individual, it is not nearly as effective as measures
! which protect the total body of the individual from
. radioactivity. Both in-place sheltering and
=
precautionary evacuations can reduce the exposure to d
the total body. As an example, if a precautionary
.vacuation can be instituted with little or no radiation exposure, this may be the most effective
" " Statement on the Use of Potassium Iodide by the Atomic Industrial Forum Committee on' Environment," cited in the " Industry g White Paper, Review of Federal Policy on Use of Potassium Iodide,"
December 1993, at 7.
4 4
I
t 10 O protective action. However, there are instances where ,
evacuation may not be preferred. Evacuation may be.
unnecessary beause the amount of protection afforded by in-place sheltering is adequate....There are also possible situations when evacuation cannot be accomplished in time to prevent exposing large numbers of individuals to a significant amount of radiation during the evacuation. In those instances where shelter is used because the evacuation cannot be completed in time to avoid a substantial radiation insult, the administration of KI could be a useful ancillary protective action which could provide some additional exposure reduction to the thyroids of the exposed individuals. The use of KI for thyroidal blocking is not an effective means by itself for protecting individuals from an airborne release of radioactivity from a nuclear power plant accident and therefore should be used in conjunction with sheltering, evacuation or other protective methods. ... !
In summary, the use of KI to prevent radiciodine from ,
accumulating in the thyroid gland can be an effective l ancillary protective action during a nuclear power i plant accident." l E. The NRC and FEMA reverse themselves. 4 For reasons that have never been explained publicly, the ,
policy statement was almost immediately scuttled. Less than three weeks after sending the draft policy statement to the Commission for approval, the staff sent a supplementary paper, SECY-82-396A (October 15, 1982), withdrawing the September 27
- memcrandum. The new memo informed the Commissioners that NRC's
- Office of Research could, by January 1, 1983, produce a paper
! showing that KI was "significantly less cost beneficial than previously assumed." The staff proposed sending this document,
- when completed, to the other federal agencies "with a 3
recommendation that a policy statement recommending against the stockpiling and distribution of potassium iodide for the general
, public be developed." The staff paper added a significant piece of information: "The Commission should also be aware that FEMA has rccently reversed its previous decision to purchase a large
- quantity of potassium iodide for a national stockpile." The
] reason for FEMA's action was not stated, however.
In a November 22, 1983 Commission meeting, open to the 4
" SECY-82-396 (September 27, 1982), Attachment 3, at 3-4.
- -. ..- -- . .. _= - _ - - .--
1 I
i 11 public, Jack Zerbe, head of the NRC's Office of Policy Evaluation, expressed his unease at the NRC staff's sudden about-face: !
i l I guess one of the things.that was of concern to us was that in 9/27/82, the staff had recommended that they
' adopt this. thing that had been worked on for four years by the three agencies, and essentially two weeks later
~they shifted that recommendation to go in just the l opposite direction.
Transcript at 79.
3 The. implied question -- why the reversal had occurred .-
went unanswered. No claim was made, then or later, that the change was based on new scientific, technical, or medical 1 information. :
l i
The purpose of the November 22, 1983 meeting was for the NRC staff to brief the Commissioners on the staff's proposal to take ;
i a strong position aoainst KI. At the outset, the three staff ;
)
briefers" emphasized that the NRC had the primary role within the U.S. Government as a source of technical expertise on the XI !
} issue." One of the briefers explained '
t i We, at the NRC, have the responsibility to provide the technical rationale and make some recommendation either for potassium iodide, a neutral statement one way or i 4
another, or against it. And that's where we have to i-come down, in some sense. It is our responsibility to provide that technical information.
i j Transcript at 7.
I A problem for the briefers, in making the case against KI, was that the Commissioners had been hearing ever since the Three Mile Island accident that stockpiling the drug was a cheap, l
['
effective, and sensible protective measure. As Commissioner Bernthal commented at one point, "I just think stockpiling is such a cheap and easy preventative, that even if the odds are 1 percent, why not?" (Transcript ac 28. )
The briefers undertook to prove that even though KI might cost only ten cents per pill, it was nevertheless not " cost-effective."
() " None of the three is still with the NRC.
- " This was correct then and remains so today.
i i l
. =- _. . .. . -. ... - . . .
l O 2 i
- The briefers'
$10,000,000 central claim was that it would take worth of KI to prevent each " nodule,"" whereas if KI were Eg1 used, the cost of dealing with each nodule that did
' occur would be at most $20,000. The transcrint is clear on this point:
At the bottom of this [ slide), you see a dashed line at about the 520,000 figure, and that represents what we feel the cost-benefit breakpoint would be. If the cost l
of averting one nodule is on the order of $20,000, that's the cost that will be. represented by the medical )
treats.ent and the loss of productivity of an individual
~
j if he had a thyroid nodule. And 3:'s on the upper end !
of the values which we have seen. There's a few days' loss from -- it's a relativelv simple operation that's
' involved in removino the thyroid or removino the nodules'l -- [ Emphasis added.]
Transcript at 52-53.
\ The briefers claimed to have performed the analysis "with a bias in favor of potassium iodide if anything." (Transcript at 53.) They continued:
And our analysis still comes down and shows that even if our most optimistic view -- which is the bottom line ,
of these curves -- would indicate that this is not a viable measure to be taken, it is not something that we should consider in terms of policy. As far as we're !
concerned, the message couldn't be any clearer. ... We have taken every factor that we can think of into account; it's not just single arguments that we throw at each other; we have factored in all the uncertainties that we can think about, and this is where we come down to it, and the message is clear.
Transcript at 54.
The transcript shows the Commissioners' response:
The $10,000,000 figure reflected the assumption that an millenium, in which KI would be useful could occur only once a accident t
" Compare in footnote this description 2, above. of thyroid disease with that quoted
~
1 Z
J 13 -
CHAIRMAN PALLADINO: But it sounds crass. It doesn't
, satisfy me as an individual.
l COMMISS10nL3 ASSELSTINE: I must say I share that view.
CHAIRMAN PALLADINO: Something just does not sit with me
- right.
(Staff briefer): Let's move on to the next slide. I
.(Laughter.)
Transcript at 54.
l .
1 i The Commissioners' misgivings were well-founded. While the j i
briefers' clear and unequivocal message was that the worst consequence of failing to stockpile XI was that a " nodule" might 1 i
appear, they neglected to mention that their figures were based not on gli nodules, but only on harmless benign ones. Their own l analysis showed that some 40% of all accident-caused nodules will )
i turn out to be cancerous, and that 5% to 10% of the cancers will be fatal."
Chairman Palladino persisted. Told that the NRC should I
' provide its cost-benefit analysis to other federal agencies and i state and local governments "because these other agencies do look {
to the Nuclear Regulatory Commission," (Transcript at 57), he replied:
I'm not ready.yet to even address that because I don't understand in the cost analysis -- for example, you say i it costs -- what were your dollars? $10 million per
~
nodule averted, and you said boy, that's. pretty high.
But then you tell me it's a low cost operation. So now to me, for example, as an individual, what would it cost me for my pill. Twenty cents. ... As an individual, I say boy, that's among the lowest-cost 1
protection. ...
I guess I was taking a more personal view of cost-benefit. 20 cents or some nominal amount of money every year or every five years to replace them seems l
~
This fact was buried in the fine print of the thick o
l memorandum that accompanied the briefing. The transcript suggests j ( that the Commissioners had not picked up on this critical point.
(
.-. .- - . . _ . . - - - - =- - -- --.- -- - - - - -- .
f f
i LO " u
! l
- like'small change compared to the risk, from my 1 l
i perception.
j Transcript at 57, 59, 60-61.
4 One of the staff briefers responded by comparing potassium j iodide to insurance policies with low premiums but with coverage j i that turns out, on close examination, to require "that there has !
j to be a stampeding elephant that kills you." (Transcript at 61.)
CHAIRMAN PALLADINO: ...You said something that bothers I l-i me a little bit. You said that we were paying a low cost for something that wasn't worthwhile. You related .
- it to a worthless insurance policy. But as an l l individual, I may say the potential benefit is that I l might survive a nuclear accident at that plant, which I j live near.
"] COMMISSIONER ASSELSTINE: Or that you may not have to l go through an operation -- 1
.. [ Staff briefer): Except that -- the survivina cuestion is not the auestion, and that's the piece that really should also be emphasized." (Emphasis added.)
CHAIRMAN PALLADINO: All right, survive in the terms of I avert --
, (Another staff briefer): 'An illness. I will avert an illness which I might incur. But my father's argument in buying his insurance policies was the very same. He
. might leave my mother $10,000 from an accident insurance policy. There was a residual chance that he would be killed by that stampeding elephant. It was not a well thought-out choice.
i " The clear implication of this statement was that potassium iodide cannot save lives. The staff briefer treated Chairman Pa11edino's comment as referring only to immediate, short-term survival. To be sure, potassium iodide will not prevent quick deaths during an accident (if people die from radiation in the short term, it will be because of whole-body doses, not thyroid doses), but it may prevent slow deaths from cancer in the years afterwards. For the three or four Americans who die of thyroid 1 (~ cancer each day, and all the thyroid cancer patients who, being i human, worry that the disease may kill them, "the surviving question" is thus very much the question.
4 1
-- -.-,+m. ,,e
v
\
15 j Transcript at 63.
- Continuing the theme that the drug was a useless remedy againest a non-existent problem, one of the staff briefers added l j that 'Se-staff did not feel it t.ecessary to come out in j oppn ton to the purchase of KI by individuals: "If somebody i
wantt ..o wear that amulet and have that available to them, that's their business...." (Transcript at 68.) l The issue was not finally resolved that day, but in the end, l the NRC's negative views on the drug were communicated to an i interagency group studying the issue." The result was the 1985 l Policy Statement, still in effect today, which declared: ,
While valid arguments may be made for the use of KI, I the preponderance of information indicates that a nationwide requirement for the predistribution or ,
stockpiling for use by the general public would not be
- worthwhile. This is based on the ability to evacuate
~
the general population and the cost effectiveness of a nationwide program which has been analyzed by the NRC...."
The net effect of the Policy Statement was to dispose of the l
Kemeny Commission's recommendation in favor of KI stockpiling, j
" I do not mean to suggest that the Commissioners remained l under the impression that thyroid cancer was never fatal. As I
! described in my Differing Professional Opinion, the Office of General Counsel pointed out to the Commission that the staff's
- figure of $20,000 referred only to the costs associated with having a harmless benign thyroid nodule. In reply, the staff acknowledged i that if both benign and malignant nodules were taken into account,
. the costs would go up by a factor of five, to $100,000. No public announcement of this was made, however, so the recalculation would i have been of no benefit to those members of the public who attended the November 22 briefing at which the $20,000 figure was touted.
. " " Federal Policy on Distribution of Potassium Iodide Around Nuclear Power Sites for Use as a Thyroidal Blocking 49ent," 50 Fed.
l Reg. 30258 (July 24, 1985). Note that the Policy Statement does not say that KI itself is not worthwhile; it is the reuuirement to stockpile or predistribute the drug that is described as not worthwhile. But the ordinary reader will not notice this artful distinction, and will understand the Government to say that the
. drug itself is worthless. Note also the implication that it will always be possible to evacuate the affected population if an accident occurs.
_ _ . _ _ _ J
. 2 O
t
' seemingly once and for all. What could not have been predicted,
! however, was that only a year 1r*.er, a nuclear catastrophe in the i soviet Union would give tangible proof of the value of the drug in radiological amargencies.
i 1
l F. ChgIpobv1 and its aftermath 1
During the Chernobyl accident of 1986, the damaged reactor
- spewed radioactive iodine not only into the immediate vicinity of
! the plant (located near Kiev in Ukraine), but also over wide !
l areas of the Soviet Union and nearby Poland. Russia, Ukraine, i and Belarus, where the distribution of KI was inadequace and untimely, are now experiencing extraordinarily high levels of
! childhood thyroid cancer, as recent newspaper articles have described." The reports from Eastern Europe make clear that l
" "Chernobyl's Young Victims Pay Toll: Thyroid, Other
, Cancers Are Belarus's Legacy of Nuclear Disaster," a front page article in The Washington Post, June 24, 1995: "In 1986, before Chernobyl, according to Yevgeny Demidchuk, director of the
- republic's Scientific and Practical Center of Thyroid Cancer in i Minsk, Belarus registered just two cases of thyroid cancer in
, children under 14, about a typical number for a country its size.
l By 1992 that number had soared to 66 cases and last year to 82, a
- surge so sudden and severe that international experts, initally skeptical about Belarus's post-Chernobyl health claims, now acknowledge it can only be explained by Chernobyl fallout. ... Pre-cancerous thyroid conditions in children are even more widespread.
1 'This is on a mass scale, several million kids who might develop thyroid cancer,' said Monoplya (director of the Radiobiology Institute of Belarus's Academy of Sciences]."
- See also, " Cancers Soar in Region of Chernobyl," The
- Washington Post, March 25, 1995: "The rate of thyroid cancer in
- a region north of the Chernobyl nuclear plant is nearly 200 times ;
- higher than normal, according to research published in the British l' J Medical Journal. Scientists from Russia, Ukraine, Belarus and the 4
World Health Organization said abnormally high rates of thyroid
- cancer in children had been detected farther away in the northern Ukraine and parts of Russia. .
... The cancer has appeared most in children because they are more sensitiva to radiation and their thyroid glands are smaller, so a given amount of radioactive iodine represents a larger dose for a child's thyroid gland than for an adult's.
... In Gomel,'a city in Belarus 70 miles north of Chernobyl, 143 cases of thyroid cancer were diagnosed between 1991 and 1994 in
- children under 15, the scientists said. That was a rate of 96.4
.per million, compared with the normal rate of 0.5 per million."
4
~- , --
4
{
j 17 d
radiation-caused thyroid disease entails much more than "a few ;
days off." In Poland, on the other hand, where KI was
~
! administered to 97% of the nation's children, there has been no similar increase in thyroid cancer. The Polish example is proof positive of the benefits of a well-prepared KI program."
In view of the grave medical news from the former Soviet Union, the United States Government is currently spending many >
I
- millions of dollars -- some of it supplied by the NRC -- to study radiation-caused thyroid cancer in Ukraine and Belarus.
3 Announcing a $15 million, 15-year program that will follow 70,000 4
children in Ukraine, the Department of Energy declared, in a June 113, 1995 press release, that the studies " provide a unique
- 1 opportunity to understand the thyroid cancer risk of exposure to radioiodine." The DOE press release explained: "The release of
- radioiodine is likely to figure prominently in any nuclear power 4
plant disaster and knowledge of its carcinogenic potency is '
inadequate, especially in children."
. In addition, the U.S. Government has spent generously to bring Ukrainian doctors to this country for training in thyroid surgery, because mishandled operations can mean damaged nerves and larynxes, and children rendered permanently mute. There could not be a better example of wise and humane foreign aid.
1 G. Post-Chernobyl develooments on KI colicy.
i The Chernobyl accident damonstrated beyond the shadow of a doubt that potassium iodide worked; that it was no mere " amulet,"
as one of the briefers had scornfully described it to the 3 Commissioners; and that countries which failed to stockpile and distribute it could find themselves with serious public health problems on their hands. The NRC staff, however, was not l immediately ready to acknowledge that the new information from Chernobyl called for a revision of U.S. policy.
In early 1989, the NRC issued NUREG-1251, " Implications of the Accident at Chernobyl for Safety Regulation of Commercial Nuclear Power Plants in the United States," in which it concluded that the Chernobyl experience did not suggest a need for changing 1 U.S. policy on KI. " Evacuation is generally feasible," it said, !
"and when carried out is more effective in dose reduction than l administration of KI, since it can reduce the dose for all body organs and not merely the thyroid gland. ... The apparently i
" Egg Nauman Er Wolff, footnote 5 above.
i i
1 4
E 1
!-. 18 5
successful use of KI at Pripyat [a city close to Chernobyl) does not alter the validity of guidance that recognizes that evacuation of the general public in the affected area could -
result in a greater overall dose reduction."" It is worth
- noting that no claim was made that evacuation was always feasible, just "ganara11y" feasible.
, H. The NRC reconsiders the KI issue.
i j In June 1989, in accordance with NRC procedures, I filed a i
" Differing Professional Opinion" urging a change in policy on potassium iodide. In order to allow the reader to understand any
- . bias that I might bring to the issue, I made clear my own personal interest
- in 1973, when I was 26, I had surgery for a l malignant thyroid t'amor, the probable result of x-ray treatment j for enlarged tonsils and adenoids when I was two years old. In 1988, my doctors detected a recurrence, which required five
- radiation trea+2ents over a three-year period to be eradicated.
{ On November 27, 1989, the American Thyroid Association wrote
- to the Commission, urging KI stockpiling on a nationwide basis.
In 1990, the NRC announced that it was reconsidering the existing
}()
federal policy." While the issue was under consideration at NRC, the World Health Organization's " Working Group on Strategy l for Public Health Action in Relation to Nuclear Emergencies"
!- issued a report stating that " implementation of [KI] prophylaxis
}- is critical," and stating: " Stocks of iodine should be stored i strategically at points including hospitals, schools, and fire
- and police stations.""
In April 1992, a contractor under the sponsorship of NRC's Office of Research issued a report which included a revised cost-l benefit analysis of the use of potassium iodide. To the credit
. of the contractor and the NRC staff, this included a serious attempt to rectify the past downplaying of the consequences of
. radiation-caused thyroid disease. As far as its weighing of l costs and benefits, however, it was bound by-the staff's j estimates of accident probabilities. Using those figures, the report concluded that stockpiling continued to be non-cost-effective, but that the difference between costs and benefits was L
" NUREG-1251, Section 4.2.3, " Assessment."
" 55 Fed. Reg. 39768 (September 28, 1990).
World Health Organization, EUR/ICP/CEH 102(S), Section 4.3.3. (1991).
l
b
- O 19 significantly in the early 1980's.
narrower than had been calculated by the NRC staff For the population within a 5-mile radius, i
i "the cost-benefit ratio for use of potassium iodide by the general public approaches a value of two," the staff. reported ir.
November 1993."
t
- In December 1993, an industry trade group, the Nuclear Management and Resources Council, sent a " White Paper" to the Commission arguing against any change in current KI policy.
i was the only group to do so.) The White Paper suggested that (It a
- change in policy would cause members of the public to "want to know are lessif the safe." federal policy is being changed because the plants It added
could be affected by the decision."""Public confidence in the technology i
j The industry White Paper also quoted Dr. David Becker, an eminent thyroidologist who is currently heading the NRC-sponsored i research into thyroid cancer in Belarus, in such a way as to make it appear that he opposed KI stockpiling. This was taking a !
af i i
- " SECY-93-318, p. 4. Thus by these calculations, KI almost pays for itself for the closest-in populations. This averaged figure does not take into account either the difference in safety j- between plants of different designs or the wide margin of error (a I factor of 100) ,in the estimates of accident probability. If
! accidents are 100 times more probable than estimated, then KI for l
these nearby residents will pay for itself 50 times over, by the NRC staf f 's own calculations.
i KI will necessarily pay for itself.
My contention, however, is not that Rather, it is that the uncertainty in the actual probability of major accidents makes these cost-benefit calculations of little value, and argues for 4
{ letting prudence and good judgment drive the decision on KI.
" Review of Federal Policy on Use of Potassium Iodide,"
Nuclear Management and Resources Council (December 1993),
l p. 8.
The industry's argument echoes the claim of environmentalists and i residents of the Three Mile Island area, in the early 1980's, that
, the NRC was required to consider the fears of the local population, and the probable " psychological impacts" on them, whether I reactor.
to allow resumed operation of the Three Mile Island Unitin determining The NRC, supported by J.dustry, took the position that a scientific and technical agency should base its decision on the best fears.available scientific and technical evidence, not on people's argued, A unanimous Supreme Court upheld the NRC, after I briefed, and lost the case in the D.C. Circuit Court of Appeals.
Metropolitan Edison Co. v. People Acainst Nuclear Enerav, 460 U.S.
766 (1983), reversing Peoole Acainst Nuclear Enarev v. NRC, 678 I
F.2d 222 (D.C. Cir. 1982).
_.____________2________________ . _ . . _ - . . _- .
20 chance, in light of the fact that Ihr. Becker was one of the signers of the November 1989 American Thyroid Association letter urging KI stockpiling, and the New York Times had published a
' letter from him to the same effect. After Dr. Becker protested, a' senior NRC official sent a letter of rebuke to the industry 4
group, declaring that its characterization of Dr. Becker's views '
was " completely contrary" to his actual position. Copies were
- sent to Dr. Becker and the NRC's Public Document Room."
I. The NRC staff backs KI stocknilino, but its cronosal for a chance in policy is blocked when the Commissioners deadlock.
i On March 29, 1994, the NRC staff declared its support for KI stockpiling. In its final memorandum to the Commission on the
- subject, it wrote:
i Although a reactor accident requiring KI is unlikely
- and KI is only effective as a protective measure for the dose to the thyroid due to radioactive iodine, the l cost to purchase and stockpile amounts sufficient to j administer to populations within five miles of i
operating nuclear power plants is relatively low. (In a footnote, the staff estimated the cost at 8.10 per i
person per year.) Consequently, it annears crudent to
, stocknile KI,for limited populations located close to i
the operating nuclear power plants." [ Emphasis added.)
The staff reported that it had engaged in dialogues with FEMA and the Department of Health and Human Services, and that the two agencies "would cooperate with the NRC in working toward adoption of a revised federal policy on KI." The staff proposed that the federal government buy the drug and make it available through FEMA to the states, which would be encouraged (but not l compelled) to stockpile it.
i On April 20, 1994, while the issue was pending before the Commissioners, Senators Alan Simpson, Republican of Wyoming, and Letter of June 1, 1994, from James L. Milboan, Deputy
- Executivs Director for Nuclear Reactor Regulation, Regional Operations and Research, to J. Phillip Bayne, President and CEO, Nuclear Energy Institute (NEI) . NEI was the successor organization to NUMARC, which was in turn the successor to the Atomic Industrial Forum of the early 1980's.
i SECY-94-087, " Addendum to SECY-93-318 Re-evaluation of i
Policy Regarding Use of Potassium Iodide After a Severs Accident at a Nuclear Power Plant," at 2.
t
- - - , , - , - . n.. .,., . ,
21 Joseph Lieberman, Democrat of Connecticut, wrote a concise and forceful letter to the Commission, urging that U.S. policy on potassium iodide be brought into line with expert opinion and international practice. After marshaling the many arguments for KI, they dealt with the claim that KI stockpiling could result in +
" negative public perception." They wrote:
[N]o evidence has been provided that any of the existing policies in other nations or in the states that provide for the use of KI by the general population has caused any undue panic or apprehension to the general public. Moreover, the federal government has a moral responsibility to provide the i public with complete and accurate information regarding )
, the risks from federally-licensed activities and ways '
j in which those risks may be reduced."
When the staff proposal came to a vote, however, the four
- Commissioners divided 2 to 2," and under NRC internal j procedures, a tie vote on a proposal means that it fails. There
- was, therefore, no decision on the merits of the NRC staff's 4
recommendation.
I J. KI and the federal aovernment -- current status.
! The tie vote on the staff's proposal for a change in policy seems to have been misunderstood completely by an interagency committee considering the KI issue. The February 1995 issue of "CRCPD Newbrief," the newsletter of the Conference of Radiation j Control Program Directors, reported that at a December 1994
, meeting of the Federal Radiological Preparedness and Coordination
! Committee (FRPCC), an ad hoc subcommittee on KI presented and j discussed a report on the drug. According to the newsletter, t-
"the subcommittee indicated that there is a lack of new data challenging the (1985] FRPCC Federal Policy" on KI. The story j . continued: "A lack of justification for a federal stockpile was identified by the subcommittee. There is also a lack of support l l for federal stockpile initiative by the states and the primary e- .
1
" A copy of the letter is attached to this petition.
'" The Commission's " Staff Requirements Memorandum" of May 6,
!. 1994 recorded Commissioner Rogers's vote in favor of the staff recommendation but was silent as to the individual positions of the l
.other three Commissioners. Commissioner Rogers is the only one of
- the four still on the Commission.
0 a ~ o,-
. - ~ .. - - . . - . - --- . -. . . - . - _ _ . ~ . _ . . ..
j j
27, l
} federal regulatory agency (NRC)."" l l' l j
The FRPCC subcommittee's position is all the harder to i
fathom in light of the publication by FEMA in September 1994 of a proposed " Federal Radiological Emergency Response Plan"" which expressly envisions the use of KI during radiological
! amargencies. Clearly, this implies that the authors of the Plan i recognise the drug's usefulness. Under the Plan, NRC will be the l
4
" Lead Federal Agency" during emergencies at nuclear power plants, j and its duties will include providing ,
... advice to State and local. governments on measures l i
that they should take to. avoid or reduce exposure of the public to radiation from a release of radioactive material. This includes emergency actions such as shelterino, evacuation, and nrochvlactic use of
- iodine."
i The Plan further provides for an interagency " Advisory Team for Environment, Food, and Health" to help the " Lead Federal
] Agency" formulate its advice, by providing, among other things,
'(
Guidance on the use of radioprotective substances (e.g.
thyroid blocking agents), including dosage and
! projected radiation doses that warrant the use of such
! drugs."
l Thus the new Plan envisions that in an amargency, the f
interagency panel will advise the NRC on when KI should be used, the NRC will then advise the state and local governments, and the i l 1 :
- " One has to wonder where the subcommittee has been ge tting l its information if it is unaware of any "new data challcogtng" the
- 1985 policy. The subcommittee might begin by reading th6 A&.4rican Thyroid Association's letter of 1989; the Marci 1994 memorandum by the NRC staff, endorsing a change in federal poticy; the April 1994 letter from Senators Simpson and Lieberman, summing up the arguments for KI stockpiling; the International Basic Safety Standards, adopted in 1994 with U.S. Government support; and the newspapers, which regularly carry articles on Chernobyl-related
, thyroid disease in the former Soviet Union.
- " 59 Fed. Reg. 46086 (September 6, 1994).
() " 59 Fed. Reg. at 46091.
l M.
i
. . _ - _ . ~ . - .. .- . --.-. . - - - . . - . - - .. . . . - _ - _ - - - - _
i I
}
23
}
states and localities will then administer the drug. What the ;
j -
Plan's authors either do not realize or do not chcose to sention !
' is that in a real emergency there will be no KI to give out, thanks to the current federal policy on the drug."
Also in 1994, the Board of Governors of the International Atomic Energy Agency, with U.S. Government support, adopted new
" International Basic Safety standards." These standards represent the consensus of the world's experts on radiation safety.
i' other things: With regard to emergency planning, they provide, among
- " Intervention levels for immediate protective i actions, includina shelterino, evacuation, and iodine i
prochvlaxis, shall be specified in emergency plans...." "
Thus the international radiation protection community, like the j
i Kameny Commission in 1979 and the short-lived draft federal policy statement of-1982, recognized that effective preparedness for radiological emergencies meant having three arrows in the quiver, not just one or two.
t LO i l
Several years ago, Dr. Jerome Halperin, wb.0 as an FDA 4 official was involved in the effort to obtain KI during the Three Mile the nation Islandwas accident lamented in a medical journal article that still in a pre-TMI state of emergancies requiring the drug. readiness for Blocker " Potassium Iodide as a Thyroid Three Mile Island to Today,"
Pharmacotherapy, Vol. 23, May, 1989. His statement was e.ccurate DICP, The Annals of l
at the time he wrote and remains so today.
" International Basic Safety Standards for Protection Against
- Ionizing Radiation and for the Safety of Radiation Sources (interim edition), International Atomic Energy Agency.(Vienna,1994), at 73. ;
i.
I i
. .__ _ _= ._ _ __ . . _ ._ _ ._ _.___._. __.__._._ __ _ _ _ _ . . _
l i 24 III. Arcument 4
! _ 1. The U.S. Government cannot rationally conclude that it i j; worthwhile to scand s15 million to study radiation-caused
! ingtoid cancer in Ukraine, but not worthwhile to spend a much smaller sum to prevent radiation-caused thyroid cancer in this country.
The project now underway to study thyroid cancer in i Ukrainian children will cost the United States about $200.00 for
! each child studied. At the same time, the U.S. Government
- refuses to spend 8.10 per child to prevent thyroid cancer in American children. To make clear, I am not criticizing the expenditure on the study in Ukraine, I applaud it. But I f
question whether, at $15 million dollars, it is 50 or 60 times -
- more valuable to the American people than would be a national !
- patassium iodide stockpile, costing a few hundred thousand dollars, that could prevent large numbers of cancers, some of 1 them fatal, in the event of a serious accident. The United States should be able to afford both." The NRC staff has estimated that KI is so cheap that buying the drug would cost less than continuing to study whether it is cost-effective to buy it. ;
Nuclear accidents can happen, here as well as abroad. If
- accidents gan happen, that means that given enough time, eventually they gill happen. If a major accident ever occurs in this country, we do not want American children go through what )
the children of Belarus, Ukraine, and Russia are suffering today. l A stockpile of KI can help assure that they do not. l This is not a radical proposition by any means. As noted l i
above, all the relevant agencies of the United States Government, !
including the NRC, initially agreed with the Kameny Commission l recommendation that KI stockpiling was sensible, prudent, and !
worthwhile. The wisdom of that recommendation was confirmed by l i Chernobyl in 1986. Whatever the reason for the Government's l abrupt reversal late in 1982, it was a serious mistake, and l correction is long overdue. I It need hardly be added that if there is ever a major
- 4. nuclear release in this country, we will spend hundreds of millions of dollars identifying, treating, and compensating harm that might
,),
~_ have been. prevented by the timely expenditure of that few hundred thousand dollars. -
- c. . .
1 4 s
i i
25
- 2. Evacuation is not necessarily the orotective measure of choice in every emeraency. and even when it is the oreferred
- option. it is not always feasible.
The 1985 federal policy statement, declaring that KI stockpiling would not be worthwhile, explained: "This is based on the ability to evacuate the ceneral nonulation and the cost effectiveness of a nationwide program which has been analyzed by a
the NRC...." 1 There are two problems with the underlined portion of this
- statement. It implies (1) that evacuation is necessarily the i protective measure of choice in every emergency, and (2) that j authorities would always havg the " ability to evacuate the i
general population." Both propositions are false, and the existing policy may therefore give states and the public a false j mense of security.
t l As the Kemeny Commission report explained (see p. 8 above),
different types of accidents, and the particular circumstances presented, may call for different protective measures. A KI stockpile assures that responsible authorities have an additional
- type of protection in their arsenal.
The NRC has never claimed, nor could it claim, the " ability to evacuate the general population" whenever a serious accident occurs. On the contrary, it has repeatedly made clear that a finding of adequate emergency planning does not translate into a guarantee that the entire affected public can necessarily be
- evacuated. The most NRC that asserts (for example, in NUREG-1 1251, issued in 1989) is that evacuation is " generally" feasible.
In the real world, unexpected things happen, such as severe weather conditions or blocked highways, that can make complete evacuation impracticable.
This means that sometimes, either by choice or necessity, authorities may be sheltering people or telling them to remain indoors rather than evacuating them. Any time that people are aheltered or told to stay indoors, it may be desirable to administer KI. In addition,.any time that evacuation routes may take people through areas of radiological contamination, it makes sense to give them KI. Finally, any time (as in the case of
, Chernobyl) that there is a large airborne release high in the atmosphere, with uncertainty about where the radiological contamination will descend, it makes sense to be ready to
- administer ?,he drug, since one cannot know whom to evacuate.
Obviously, you do not have the option of administering XI if
l O 2e
- there is none to administer."
! - The opponents of KI often make the argument that to be in l i
favor of KI stockpiling amounts to downplaying the importance of ,
evacuation. Evacuat'.on protects the whole body, they say, whereas KI protects only_the thyroid gland, so to support !
stockpiling is to indicate a willingness to leave the rest of the l body at risk from radiation, thereby diminishing public i protection. This argument is factually incorrect, illogical, and disingenuous. The advocates of KI stockpiling, from the Kemeny Commission through the International Basic Safety Standards, have always envisioned the drug as complementing other emergency planning measures, not replacing them. There is no way that the availability of KI could increase risk to the public. Would the d
existence of a supply of pills on a shelf in local schools and firehouses cause all the public officials responsible for
- managing radiological emergencies to forget about evacuation as 2 an option if an emergency occurred? Would it impede an
- evacuation? Of course not.
t
- 3. The decision on stockpilina KI should turn on whether, i civen the enormous consecuences of beina without it in a maior accident, it is a crudent measure, not on whether the drua will necessarily cav for itself over time.
5 The opponents of KI have framed the issue in terms of j whether the drug is " cost-effective" -- that is, whether it would
- pay for itself over time in terms of reduced medical expenditures
- to treat radiation-caused thyroid disease. The implied premise is that if KI is not cost-effective in dollar terms, it is therefore not worth having.
i
. That premise, however, is false. KI, like all other emergency planning measures, represents a kind of catastrophic-coverage insurance policy, offering protection for events which, while they occur only rarely, have such enormous consequences i when they do occur that it is sensible to take special h
" Compare the point made by Commissioner Rogers, in voting for !
the staff's recommendation, as recorded'in the NRC Secretariat's
" staff requirements memo" of May 6, 1994: " Commissioner Rogers O believes that, in order for FEMA, State or local authorities to have a viable option for a KI program, it would be prudent for the U.S. government to assure the availability of a supply of KI."
i O precautions."
Health and life insurance policies are not intended to be cost-effective for the average purchaser. (If they wgIn cost-effective, every insurance company would go bankrupt.) Does that mean that people are foolish to carry insurance? Of course not; it is the people who fall to carry 2
insurance who are considered foolhardy. In addition to buying insurance, we spend money on countless other preventive measures in everyday life -- vaccinations for our children, smoke detectors and fire extinguishers for the home, a first aid kit for the car -- because they are sensible, not because we ,
necessarily expect them to pay for themselves.
The best analogy to KI may be the lifejackets that ferryboats carry. We start with the assumption that ferryboat sinkings are unlikely, and we readily acknowledge that if an accident does occur, it is better to leave the ship in a lifeboat
' than bob in a lifejacket in the water. But sometimes things do not happen in real life the way they happen in drills. If there is no lifeboat available when the ferry sinks, the lifejacket may keep you from harm while waiting to be rescued, and if no lifeboats can be launched, you are better off with a lifejacket than with nothing at all. So we equip our ferries with
- O lifejackets; we do not spend more money than the lifejackets themselves would cost studying whether to buy them; and we do not find the ferry operators writing White Papers to prove that if passengers knew that there were lifejackets on board, they would be too frightened to travel by boat.
- 4. The estimates of KI's " cost-effectiveness" all deoend on estimates that are no more than informed cuesses about the probability of severe accidents.
The cost-benefit analysis upon which the current KI policy is based relies on certain assumptions about the probability of severe accidents. Those assumptions need to be recognized for what they are: informed guesses, not hard facts. The NRC's cost-benefit analysis of the early 1980's was based on'the assumption that a severe accident with a major release of
" At the 1983 Commission meeting on KI, one of the briefers compared KI to an insurance policy which, when you read the fine print, covers only death by stampeding elephants. The problem with this analogy is that the United States has never to my knowledge experienced an elephant stampede, and it is never likely to. The 7-~ United States has, however, experienced the partial meltdown of a (j nuclear power plant (at Three Mile Island), and it could do so again.
J-
! 28 i
radioactivity could occur in this country only once every 1000 -
~
years (with 100 reactors operating). But the all-important margin of uncertainty was huge: the agency acknowledged that accidents might be as much as 100 times more likely than that.
In the past, optimistic predictions have not always been borne
- out by evente. The Three Mile Island accident was also
- considered highly improbable, until it happened.
4
, If it were really true that serious accidents with a release of radioactivity "can't happen.here," than there would be good reason not only not to reject stockpiling of KI, but alsd to
- dispense with all the rest of amergency planning. One could then ,
4 ignore Chernobyl, and disregard the use of KI in the rest of the I
, developed world, by saying that while foreign reactors may suffer i serious accidents, ours will not. But the NRC has never claimed j' that accidents in this country are impossible. In 1985, the same year that the current policy statement was adopted, the NRC
, Commissioners were advising the Congress that the estimated likelihood of a core melt accident at a U.S. reactor by the year l 2000 was 45%."
jO - Granted, not every accident results in a core melt, and not every core melt accident necessarily leads to uffsite releases. .
One can be quite sure, however, whenever there is a serious accident, authorities will be looking for KI just in case it progresses to the point of a large offsite release. (We can assume that for every catastrophic accident, there will be a i number of these lesser accidents.) Thus it is not sufficient to say that accidents with major offsite releases occur only rarely; l the more relevant question is the chance of an accident serious enough to make authorities start hunting for a supply of KI. i j 5. If KI is not cost-effective, the rest of nuclear emeroency olannina is erobably not cost-effective either.
! The argument that KI should not be part of radiological l l emergency planning because it is not " cost-effective" carries the '
implication that those measures which AIR currently part of NRC-required amargency planning (sirens, exclusion zones, periodic 4
emergency exercises, etc.) have besn found to be cost-effective.
This is not the case. KI is the only emergency planning measure
- to have been scrutinized with a cost-benefit analysis. The NRC's Advisory Committee on Reactor Safeguards pointed out lorg ago that all the other elements of the NRC's amargency plan Eng requirements (such as sirens and periodic amargency exes
- ises)
The New York Times, April 17, 1985.
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29 4
were put in place without a cost-benefit analysis and might well not pass.that test.*' If serious accidents are really possible
- only every one or two thousand years, it is unlikely that any
' element of current nuclear amargency planning could be found
" cost-effective," in the sense of being likely to pay for itself j over time. Does that mean that the United States should leave
- the public at even greater risk by declaring that for American reactors, no emergency planning whatsoever is necessary? Of course not.
- 6. Cost-benefit analysis is a techniaue that needs to be moolied with oood sense, esoecially where oublic health meaggggg are concerned.
1 Cost-benefit analysis, as valuable a tool as it can be when properly applied, needs to be performed with a measure of good
. sense, which includes a recognition that sometimes, costs and/or benefits may not lend themselves to quantification in dollar terms. This is particularly true in the area of public health.
, Here, the evaluation of KI that preceded the 1985 federal
. policy statement was of a kind to give cost-benefit analysis a l l
bad name. Strictly limited to economics -- the dollar costs of l KI pills on the one hand, the dollar costs of having radiation-
- caused thyroid disease on the other -- it wholly ignored the quality-of-life impacts of thyroid cancer and other radiation-caused diseases.
I Common sense tells us that if given a choice between a case l of disease prevented and a case of disease cured, we would all j prefer the former, even if the cure did not cost us a penny. But l the cost-benefit analysis of KI proceeded from the assumption i that there was no difference in desirability between prevention of radiation-caused thyroid disease and cure; thus the only
- factor to be considered in evaluating KI was the difference in cost. The old proverb that an ounce of prevention is worth a pound of cure went out the window, as the U.S. Government
The ACRS said: "The risk-benefit analyses conducted by the NRC .etaff on this subject do not appear to be compatible with (or comparable to) approaches used in evaluating other aspects of nuclear emergency planning. For example, if the same evaluations were made, would there be justification for the conduct of emergency drills or the installation of warning sirens? Similarly 4 the question could be raised as to whether there would be justification for population evacuations." Attachment to SECY 362 (August 30, 1983).
1
6 $
i
- 30 determined that instead of spending money to prevent radiation-caused thyroid disease, society should spend its money treating
~
the. disease if and when it occurred.
l i Any child knows that the negative impacts of illnesi are not
, limited to the economic costs. Any parent knows that people do not immunize their children against polio and diphtheria primarily to save money. In the real world, people pay to j l
j immunize their children against diseases first and foremost to spare them the misery and the danger that go with these
- illnesses.
- But the cost-benefit analysis of KI ignored that obvious
- point, and as a result, it was valueless from the start. Indeed, i it was worse than valueless, because it provided a
- rationalization for ignoring the Kemeny Commissior.'s sensible recommendation in favor of KI stockpiling. The r.on-economic
} impacts of illness may be difficult to translate into dollar i terms, but that does not mean that they can be ignored.
- 7. The existino oolicy on KI was defective from the start,
]
as it was based in cart on inaccurate information orovided to the i NRC Commissioners.
Decisionmakers who must weigh costs and benefits also need i accurate data. The transcript of the 1983 staff briefing makes clear that the information provided to the NRC Commissioners seriously understated the significance of radiation-caused thyroid disease and thereby understated to an equal degree the i value of KI. The briefers' central failure was to mention that i
when referring to " nodules," they were not taking into account the 40% of nodules that would be cancerous. It is as though
~
staff members of the Department of Transportation informed the
- Secretary that airbags were of no value in " collisions" without l mentioning that their definition of the word excluded every collision more serious than a fender-bender. Whatever additional information the Commissioners later received on the subject of thyroid disease, it is not at all clear that the Commission had any idea of the real nature of post-accident thyroid disease at the time they adopted an anti-KI pocition. Certainly, the oublic never received notice that the information provided at the 1983 meeting was erroneous.
- 8. Existina policy ouroorts to leave the iudament on stockeilina KI to the states, but assures that the states do not
- have an adeounte basis for makino informed decisions.
In theory, the existing federal policy on KI leaves the 1
l
(
4 O 31 decision on stockpiling to the states. Since 1983, however, the federal government, and NRC.in particular, have failed to provide
_ the states with sound technical advice on the subject. Without 2 accurate and current information on KI -- including the Chernobyl experience and the consensus of international experts -- states -
cannot make an informed judgment.
In their April 1994 letter to the Commissioners, Senators Simpson and Lieberman said pointedly that "the federal government
, has a moral responsibility to provide the public with complete and accurate information regarding the risks from federally-licensed activities and ways in which those risks may be
! reduced."
i Since that time, however, the government's record on providing the public with " complete and accurate information" has
- actually taken a turn for the worse, with the publication in 5
September 1994 of FEMA's " Federal Radiological Emergency Response Plan." As described above, at p. 22, the Plan provides that in an emergency at a nuclear power plant, an interagency Advisory Team will provide guidance on KI to the NRC, and the NRC will
" provide advice to State and local governments on measures that
- O. they should take to avoid or reduce exposure to the public,"
including " sheltering, evacuation, and prophylactic use of iodine."
No, state or local official or member of the public, reading this Plan, could possibly imagine that in a real emergency, there would be no iodine to administer. This raises a number of
- _ questions. If KI stockpiling is not worthwhile, why is administration of the drug one of the protective measures l identified in the Plan? If KI 1A worthwhile, as the Plan implies, why isn't something being done to make sure that it is
( available? Does FEMA not know the actual state of KI preparedness?
The federal government cannot have it both ways. Either it should change the 1985 policy, and make the use of KI a viable option in a real emergency, or it should explain loud and clear why the United States has decided that XI will not be an option.
What it cannot responsibly do it withhold protection, on the one hand, and on the other hand, represent to the public that this protection is already in place.
l l
32 IV. The Remedy The purpose of this petition, which takes the form of a rulemaking petition under 10 CFR 5 2.802, is to raise the l potassium iodide issue before the Commission and ensure that it receives a definitive resolution. ,
l My specific request is for a minor change in the NRC's i
existing emergency planning rules, 10 CFR 5 50.47. These rules include 16 planning standards by which emergency plans are to be )
evaluated. The tenth of these standards reads as follows:
(10) A range of protective actions have been developed j for the plume exposure pathway EPZ [ Emergency Planning I Zone] for emergency workers and the public. Guidelines ;
for the choice of protective actions during an I emergency, consistent with Federal guidelines, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
5 /
I propose that the NRC amend this provision to read, "A '
1 range of protective actions, includina shelterina, evacuation, and crochvlactic use of iodine, have been developed..."
i This language is taken verbatim from FEMA's September 1994 Federal Radiological Emergency Response Plan. If this change is
- adopted, the Plan will become an accurate description of emergency preparedness for radiological emergencies; the -
recommendation of the Kemeny Commission will at last be implemented; and the United States will be in compliance with the International Basic Safety Standards.
I suggest that the NRC also issue, either or its own or in conjunction with other agencies, a policy statement declaring that KI stockpiling is a sensible and prudent measure, necessary to assure that the drug will be available in the event of a major accident. (This policy statement could be modeled on the excellent draft statement of 1982, which regrettably was 4
withdrawn.) This statement would make clear that KI, while no
, panacea, can be used in conjunction with evacuation and sheltering to maximize protection to the public.
I am not proposing house-to-house predistribution of KI, O which I think would be inef fective and a source of confusion during an actual emergency. Rather, I am suggesting that state and local authorities have ready access to supplies of the drug so that they
)..
4 l
33 j The policy statement would also state the willingness of the j NRC to provide a stockpile of the drug to states and localities
- - upon request (unless FEMA or some other federal agency is i
prepared to do so). In addition, the statement would support the Kameny Commission's recommendation for the creation of regional j- stockpiles of the drug as a backup for amargencies.
i l This policy would mean negligible cost to utilities.
Contrary to the apprehensions of the nuclear industry, it would i not send a message that nuclear plants have suddenly become more I dangerous; it would simply mean that the U.S. Government,
- figuratively speaking, was_ putting a first aid kit into the car, 4 after having neglected to do so for far too many years. Would
- members of the public suddenly become newly frightened of nuclear accidents because XI is being stockpiled? As Senators Lieberman and Simpson pointed out, the presence of KI does not seem to have panicked the population in the places where it is stockpiled j today, and there is no reason why it should. If the World Health j Organization recommendation is followed, and KI is stored l strategically ~in firehouses, hospitals, police stations, etc., 1 few people are likely even to be aware that the drug is being stockpiled.
[ ,
! The amount of potassium iodide stockpiled around each nuclear plant would not be great. Most nuclear plants are sited
' away from large concentrations of population in order to keep down the risk to the public. In an amargency, the drug might be needed in a wider arr,a than just the immediate radius around the 1
! came to ground far downwind), but the existence of regional
' stockpiles would mean that the nation had a backup supply to draw upon in case of need.
i-If there should ever be a nuclear accident in this country serious enough to make authorities need KI, or even consider its use, and there was no XI to be found, what would the American people say? The anger and recrimination afterwards would be enormous, both for the failure to protect and the failure to inform. NRC, having promised in 1979 to put a KI program in l place and then not done so, would have the most to answer for, l especia?.ly in light of the the wealth of recent data from 1
- Chernobyl on thyroid effects and the 1994 recommendation of its i own technical staff in favor of stockpiling. FEMA would be in
- - the unenviable position of having to explain why its 1994 Plan l F implies not only that KI is valuable in emergencies, but also can administer it if it is needed.
1 i
._,,-,.--m--- -
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4 i
that it is currently available, f-But pointing fingers after the fact will do no good to any child who got a dose of radioactive iodine in the thyroid because KI was lacking when it was'needed. We cannot afford to wait until another accident or near-accident, and the resulting hue j and cry, compel a change of policy. There is ample evidence now
- .that the current policy is ill-founded, irrational, and dangerously complacent. The-time to put a lock on the barn door
- is before the horse is stolen. If it should turn out that.no attempt to rob the barn is made in our lifetimes, so much the better -- it's a very cheap lock.
j Today, the Nuclear Regulatory Commission has the opportunity and the responsibility to resolve the XI issue ,
sensibly and straightforward 1y, as the NRC staff proposed doing l in 1994. There is no good reason why American children should l continue to be unprotected with KI, when the governments of other l developed countries around the globe provide this cheap and j effective protection for their children as a matter of course.
The NRC staff has pointed the way, and the Commission and the Federal Government should follow.
Attachment:
Letter of Senators Alan K. Simpson and Joseph I. Lieberman, April 20, 1994 i
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! ._ April 20,1994 i
i I
The monorable Tvan salin l Chairman i 9.8. Nuclear Regulatory Cosmission Washington, DC 20555 l l
l
Dear Chairman Salin:
- we are writing to urge the Nuclear Regulatory Commission ,
(NRC) to revise its current policy reearding the availability and !
! use of potassium iodide (KI) in the event of an emergency at a '
- nuclear power plant. ;
i The NRC's current policy is that state and local governments
! should consider stockpiling KI for emergency use by emergancy I workers and institutionalized persons, but not for the general 1 public. This policy was established in the early 1980's. Since
- that time, however, new information has arisen and additional
- experience has been gained on the costs and benefits of the i prophylactic use of K1 by the general population. We believe l that this new information and experience requires a new approach l to this issue.
It is well established scientifically that KI is extremely effective in preventing the uptake of radioactive iodine by the I
thyroid. If taken in the proper dose prior to exposure to l
radioactive iodine, x2 can completely block the uptake of the radioactive iodine, l, The distribution of Kr to the seneral population in the
!. event of a nuclear emergency is a widely accepted protective l snessure. The World Meelth organisation hem recusenended Ate use j for people living naar a nuclear power plant if radiation levels
- are expected to exceed a predetermined dose. A number of ferai governmants -including the United Kingdom, the Csach Republic, gn Switserland, Canadian provinces with nuclear power plante, and
, the former Soviet Union.. stockpile R2 for distributlen to and use
- by the general public in the event M a nuclear emergency. In
> *the U.S., three states Alabama, Tennessee, and Arizona..have
, piens to distribute or already have distributed RZ to people
- living near one or more nuclear power plants within those states.
O l ser.us e ureensee. pen
~
1 A recent cost benefit # udy of this issue conducted for the
- RC indicates that the oostw of stockpiling EI for people who
- live within five miles of a nuclear power plant are mintaal -
approxlastely ten cents per person per year. This means that for 4
a typical population of 10,00.S people living within five miles of i e auclear power plant, it would cost approximately $1,000 to make 1 _. II available for distribution. The IRC staff projecto that the j oost of stockpiling sz for everyone in the sountry witain give
- miles 7f a nucisar power plant would be on the order of several j hundred thousand dollars per year. This is only a small fraction
- of the expenses already spant on amerTency planning. As the R C l i staff has acted, *(closta in this range present no significant l harrier en eteekp111og and are probahay less than the most of the
> eentinued studies.*
i l l Some concern has been expressed that public education on the 1 i use cf KI may result ir. a potentially significant negative public i perception. Mowever, so evidence has been provided that any of ;
the existing policies in other nations or in the states that 1 previde for the use of KZ by the general population has caused any undue panic or apprehension to the ganaral public. Moreover, !
' the federal government has a moral responsibility to provide the )
public with complete and sceurate information regarding the risks ,
l from federe11y 2teensed activities and ways in which those risks i j may be reduced. J
! In sum, therefore, KI can be an extremely effective
- countermeasure to prevent damage to the thyroid in the event of a radiological emergency. It can also be made available for the l general population living near a nuclear power plant for minimal costs. The NRC should revise its policy to provide this
- additional potential protective measure for nuclear emergency planning.
we thank you for your time and consideration.
! sincerely, l _
l
~
l Alan . inFpson 01 ph I. Lieberman l Ranking stinority member c ruan subconmittee on clean Air subconnittee on Clean Air ~
an6 Nuclear Regulation and Nuclear Regulation
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f STATEMENT OF PETER CRANE
- Before the Maine Advisory Commission on Radiation
! . Hollowell, Maine j December 6,1996 4
I My name is Peter Crane, and I'm from Chevy Chase, Maryland. I am Counsel for Special MQ. cts at the U.S. Nuclear Regulatory Cnemiazion, which I joined in 1975. I've been there ever since, exmpt for a period in 1991-92 as l an administrative judge in the Republic of the Marshall Islands, in the Central l
Pacific. I'm here today in my private capacity, not as a representative of the NRC.
i
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