ML20205L063

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Transcript of 990301 Potassium Iodide Core Group Meeting in Tempe,Az.Pp 1-104
ML20205L063
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Issue date: 03/01/1999
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Download: ML20205L063 (106)


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UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

4 POTASSIUM IODIDE (KI) CORE GROUP MEETING 5

6 AmeriSuites Hotel 7

1520 West Baseline Road 8

Tempe, Arizona 9

Monday, March 1, 1999 10 11 The above-entitled meeting commenced, pursuant to 12 notice, at 2.00 p.m.

13 ATTENDEES:

14 ABY MOHSENI, CHAIRMAN 15 BILL MCNUTT 15 MARCIA CARPENTIER 17 JIM HARDEMAN 18 ANDY SIMPSON 19 AUBREY GODWIN 20 JOELLE KEY 21 MIKE CASH 22 TONY SHERIDAN 23 MIKE NAWOJ 24 ANDREA PEPEER 25 MIKE JAMGOCHIAN

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PROCEEDINGS

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2

[2:00 p.m.]

3 CHAIRMAN MOHSENI:

We'll begin our meeting which 4

is open to the public.

This is the second meeting of the KI 5

Core Group.

We will go around, introduce ourselves, but 6

before we do that, I'd like to thank Aubrey Godwin for 7

helping us host this meeting in Tempe, Arizona.

And do you 8

want to give us a brief description of where we are and what 9

all the rules are and where we can have lunch, dinner and 10 everything else that goes with it for the next four days?

11 MR. GODWIN:

Well, most of you have found out your 12 on a mall site and the mall has a food court in it so that's 13 a quick area to get food at.

You also can leave a little 14 money there which will help the people in Tempe and Chandler

(

15 and several other cities because they share the revenue out 16 of the mall here among several cities.

17 First of all, I would like to welcome you on 18 behalf of Governor Hull.

We're happy to have you all here.

19 We appreciate you taking the time to come and visit with us 20 and hope you'll find some things you'll like and come back 21 and visit us again.

22 For more elaborate meals, there's a place straight 23 out the front door, it goes almost a block but it's across a 24 little drive-in area, called the Rusty Pelican which has 25 pretty good seafood, now this is Phoenix pretty good.

It's 0'2 1

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not going to'be Louisiana and Mobile, but it's pretty good 2

seafood.

3 MS. KEY:

We're planning dinner.

4 MR. GCDWIN:

Then if you have a car, on up the 5

road toward the west will be the Pointe Hilton which has 6

several restaurants there.

They have a Mexican restaurant, 7

a western restaurant and a very formal dinner type 8

restaurant.

So those are reasonably close.

Shoney's was 9

open when we started booking this place but Shoney's has 10 since closed.

So I'm not sure that you missed anything 11 there but it did close.

It was across the street.

12 MS. KEY:

Is there any place within like walking 13 distance for like grocery type things?

14 MR. GODWIN:

The closest thing would be a K-Mart

()

15 which would be to the east of here about three blocks.

16 Okay?

The front door faces west, okay, that will give you a 17 clue.

Now, if you have cars, I'll try to have a map over 18 here tomorrow and show you some things on down the strip.

19 Each mile down the interstate there's an exit and around 20 each one of those is several places to eat, placed of 21 entertainment.

But movies theaters are over there.

22 MS. KEY:

Yeah, there's an I-Max and it looked 23 like a good show.

I'm planning on hitting it one night this 24 Naek.

25 MR. GODWIN:

Yeah, it's a pretty nice area.

The i

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only downside if you go to the lake, you may have to walk

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2 all the way around the mall instead of through the mall 3

coming back.

That's one thing you need to keep in mind.

4 Thank you.

5 CRAIRMAN MOHSENI:

Great, tnank you.

You all I

6 realize this is a meeting open to the public.

This is being 7

transcribed and it will be on the Web page of the NRC i

8 similar to the first meeting.

There are certain rules we 9

have to follow because it's being transcribed.

Number one, 10 everyone cannot talk at once, unlike what we usually are 11 used to.

12 Two, folks in the area, people who are not part of 13 the KI Core Group, will have essentially a lot of 14 opportunities to make comments and for them, there is a

()

15 microphone back there.

If you would, stand up, go to the 16 microphone, introduce yourself.

Probably the first time you 17 may have to spell your name so that we get it right.

18 Subsequent to that, you probably just say who you are is 19 enough.

You don't need to spell it again.

20 Let's go around, introduce ourselves.

I'm Aby 21 Mohseni.

I'm with the U.S. Nuclear Regulatory Commission 22 working on this task group or KI Core Group.

23 MR. HARDEMAN:

I'm Jim Hardeman with the Georgia l

24 Department of Natural Resources and I'm here representing 25 Conference of Radiation Control Program Directors and chair j

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of the Emergency Response Planning Committee.

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2 MS. PEPPER:

I'm Andrea Pepper with the Illinois l

I Department of Nuclear Safety.

4 MS. CARPENTIER:

Marcia Carpentier, Radiation 5

Protection Division of EPA.

6 MR. SIMPSON:

Andy Simpson with the Pennsylvania 7

Emergency Management Agency here representing National l

l 8

Emergency Management Association.

l 9

MR. NAWOJ:

I'm Mike Nawoj with the New Hampshire 10 Office of Emergency Management.

j 11 MS. KEY:

I'm Joelle Key with the Tennessee 12 Division of Radiological Health.

13 MR. CASH:

I'm Michael Cash with the Alabama 14 Department of Public Health, Office of Radiation Control.

()

15 MR. GODWIN:

Aubrey Godwin, Radiation Regulatory 16 Program in Arizona.

17 MR. JAMGOCHIAN:

Mike Jamgochian, Nuclear I

18 Regulatory Commission.

19 MR. BORDER:

Harry Border, State of Arizona, 20 Division of Emergency Management 21 MR. LANTZ:

Mike Lantz, Arizona Public Service.

22 MR. MADDOCK:

Marion Maddock, Southern Nuclear 23 Operating Company, Emergency Planning.

24 MR. COWLEY:

Dick Cowley, Washington State 25 Department of Health, Radiation Protection.

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1 CHAIRMAN MOHSENI:

Thank you.

We have on the

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2 agenda a review of our agenda for the next few days.

There j

3 are some changes to it as we will discuss shortly and then 4

agree on what we're going to do the next few days and 5

accommodate the members of the KI Core Group here.

The 6

agenda has Jim Hardeman this afternoon and tomorrow morning.

7 Jim worked on th9 accident plans at nuclear power plants and 8

he also worked on the Chernobyl experience as it relates to 9

the U.S.

10 MR. HARDEMAN:

And I think we may be able to get 11 both of those in this afternoon if that will make -- because 12 I was, until Charlie's passing was depending on him to do 13 most of the Windscale and TMI stuff, so -- but I think we 14 can muddle through.

()

15 CHAIRMAN MOHSENI:

By the way, as you noticed, as 16 you all are aware, Charlie Willis passed away unfortunately 17 and not only as a human being we sorely miss him but also as 18 a top notch expert in the filed of radiation and emergency 19 planning and we have a very difficult time to replace 20 experts such as Charlie.

We will, however, reach out in the 21 NRC and bring more people.

Maybe more than one person is 22 needed to fill in the shoes for it.

23 And he's got most of the stuff written and given 24 to us and you all have copies of his write-up.

We will all 25 have to make changes as necessary to accommodate what the O'

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1 report requires with other experts that we can find in the 1 ()

agency.

If that is the case then, Jim, the time tomorrow 3

that would be available to us, we would like -- I'm l

4 proposing that we review the comments that we have received.

5 To some extent, I've distributed them to you by E-mail, but 6

I do have also some comments that are hard copy and I got as 7

late as Friday, so I didn't have a chance to distribute that

}

8 to you.

9 We can probably ask Aubrey to -- I can give him 10 some copies so that if there's a chance to get extra copies 11 for us for tomorrow, go over those, review those comments.

12 We have a comment from Ohio's citizens group, another from 13 Ohio State Radiation Program, one from a Massachusetts 14 citizens group, another one from San Luis Obispo Health

()

15 Department and one from Wallace Labs.

16 We will review those comments 9:00 o' clock 17 tomorrow morning and I don't see any other changes right now i

18 in our agenda.

Ed Wilds informed me that he will be here 19 later because the Governor of Connecticut asked him to go to 20 another meeting on Monday, so he will try to be here for 21 Wednesday, for our Wednesday meeting.

We have now Tony 22 Sheridan joining us.

So with that minor change in our 23 agenda, I think we can proceed.

I would like to start off 24 by -- oh, Bill McNutt as well has arrived.

25 MR. McNUTT:

Good afternoon.

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CHAIRMAN MOHSENI:

Thank you, Bill, welcome.

2 Marcus, welcome.

I would like to remind everyone of our 3

task one more time.

Following direction given to the 4

Commission by the NRC staff, in revising a draft new reg 5

document, the staff determined that a KI Core Group should 6

be formed comprising of representatives from those states i

l 7

that have KI as a supplemental protective action.

Those are 8

Alabama, Tennessee and Arizona, the Emergency Response l

9 Committee for the Conference of Radiation Control Program 10 Director, CRCRP and the U.S. FDA and U.S. EPA and FEMA.

11 The goal of the KI Core Group is to develop a 12 revised draft new reg and an accompanying draft user 13 friendly brochure to support emergency planning decisions on 14 the role and use of KI in site specific emergency plans.

15 The revised new reg will take into account the many useful 16 public comments received and will discuss the factors that 17 need to be weighed in state and local decisions on the role 18 of KI under their specific local conditions.

19 It will also discuss in some detail the various 20 guidance on the issue in the World Health Organization, 21 IAEA, International Atomic Energy Agency and the U.S. Food 22 and Drug Administration documents and will include the l

23 discussion on how the practical problems in KI stockpiling, 24 distribution and use are handled in the states and numerous 25 nations which already plan to use KI as a supplemental h

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protective action.

The proposed user friendly brochure will 2

provide an abbreviated discussion of the factors which need 3

to be considered by emergency planning decision makers in 4

recommending general public use of KI and practical I

solutions to potential problems with KI stockpiling, 5

6 distribution and use.

7 As a member of the KI Core Group, you are all 8

asked to help us put those two documents together.

In a 9

broader perspective, in the area of a revision to the KI 10 policy, there are four large projects that have impact on 11 this thing taking place at the same time.

Number 1, NRC has 12 embarked in a rulemaking process, as you all are aware.

13 Number 2, the FRPCC is involved in revising the federal 14 policy on KI.

Number 3, this document that you're working j

15 on which is the guidance document to be used by those states 16 who ultimately are asked to consider whether or not KI 17 should be added.

This is that document that they will use 18 to make that determination.

19 And Number 4, the Federal Government has 20 undertaken a very large project on preparing for nuclear 21 biological and chemical threats and there has been 22 discussions about whether or not KI ought to be added to I

1 i

23 that list, whether or not that should become recognized as I

24 part of the federal policy on our side of the world. 'All i

25 that is whether or not, so it's not given, it's not cast in l

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concrete.

We do know that the supplies are very 2

extraordinarily limited as we speak right now, to the point 3

that reliance on those may not be an effective thing to do 4

as we stand today.

Whether that's going to change in the 5

future, we don't know.

6 The four projects are expected to ultimately come 7

together by the end of this year are the rulemaking, the 8

guidance document that you all are working on, the FRPCC 9

position as ultimately finalized in the Federal Register 10 Notice and whether or not it takes -- recognizes NBC 11 stockpiles.

All those will have to come together by the end 12 of the year.

That's our target goal.

We all know that we 13 will hear much more on Thursday that the FDA has accepted to 14 revisit its position on KI.

Whether or not that results in 15 any changes, we don't know.

The fact that HO's draft 16 guidance is out for comment and it's a working document has 17 also caused FDA to revisit its policy based on the 18 information that led to WHO, World Health Organization, to 19 make some changes to its policies and guidance.

}

'20 Those are critical elements of this development.

21 This document will have to rely heavily on what FDA 22 ultimately comes out with.

So there's a section reserved 23 for FDA in this document.

The timing of FDA's contribution 24 in this document is of -- I wouldn't say concern, but it is I

25 something we are looking at to make sure that everything

[]

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comes togetbir in a timely fashion.

Having said that, if

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2 you all don't have any more comments, we will turn over to l

3 Jim for the discussion on severe accidents.

4 MR. HARDEMAN:

Before I kick that off, I notice 5

that every other day has got a public comment period --

6 CHAIRMAN MOHSENI:

Correct.

1 7

MR. HARDEMAN:

-- except for today and I was 8

wondering if it might be appropriate if any of the members 9

of the audience have anything they'd like to say before we l

10 get started, you know, if we could take just a minute to see 11 if anybody had a comment.

12 CHAIRMAN MOHSENI:

Very well, if you'd care to 13 comment anyoru, any new member.

14 MR. HARDEMAN:

I just wanted to ask, I'm trying to 15 stall.

I 16 CHAIRMAN MOHSENI:

Also please note that New l

l 17 Hampshire, we have Mike from New Hampshire who joined -- is 18 joining us for the first time in the KI Core Group.

He's 19 not a member of the KI Core Group.

However, we will use 1

20 Mike's insights as if he is.

The reason we're not expanding 21 this thing is because at this point in time it is --

22 probably the second meeting will result in a draft document 23 but it's -- we've always invited to get more public and 24 state comments into our process.

So, yes?

25 MR. GODWIN:

One comment on some of the things you t

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said, Terry's group is being funded through the Defense

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2 Department, the Justice Department, I'm not really sure 3

which.

Some of the cities are buying KI, so be aware that 4

there are some cities that are buying KI as part of that 5

stockpile. They're getting cleared to buy it.

6 CHAIRMAN MOHSENI:

Give me an example.

7 MR. GODWIN:

Phoenix.

8 CHAIRMAN MOHSENI:

Very good, very good.

How 9

much, do you know?

10 MR. GODWIN:

I think it's 500 bottles but they 11 didn't talk to me.

They just said, "We're buying it",

and 12 announced it one day and I said, "Well, who's going to 13 authorize it to be used and all that", and they said, "Well, 14 we think you are".

And I'm going, " Hello".

(

15 MR. JAMGOCHIAN:

And how much had they involved 16 you in the planning effort?

Did they happen to mention for 17 what they were buying it?

18 MR. GODWIN:

They didn't talk to me about 19 anything.

I did raise the question --

20 MR. JAMGOCHIAN:

They're just buying KI because --

21 MR. GODWIN:

It's one of the things on the list.

22 MR. JAMGOCHIAN:

No, I understand.

But my point 23 is, why is it on the list?

I mean --

24 CHAIRMAN MOHSENI:

It's our fault, We requested 25 it.

NRC requested it a few years ago when this development O

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was occurring that we asked U.S. Public Health Service which

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2 is in charge, by the way of developing that list that's put 3

in front of all the cities that they are planning for, that 4

if they would add potassium iodide to the list of all the 5

stockpiles of antidotes and stuff so that somewhere in this 6

country we can actually have some KI.

l 7

MR. JAMGOCHIAN:

So then the question is to 8

protect them from Iodine 131.

Were does that come from?

l j

9 CHAIRMAN MOHSENI:

That's a very good question, 10 Mike, but we did not go into the depth of actually coming up 11 with a credible scenario that would actually say, "This is 12 how this becomes useful", but at least I know that this is 13 how it began; the request went from the NRC and they put it 14 on the list but what we had heard back, Aubrey, was that not

()

15 too many cities had opted to add KI because when they looked 16 at the biological and chemical, the associated risks and the 17 reaction to it, like antidotes for anthrax and antidotes and 18 blood and antibiotics and all that stuff did not -- were not 19 at the same level as potassium iodide even in a scenario 1

20 that wasn't even written as to what that scenario is.

21-But we know to that extent that we asked and l

22 Public Health Service put it on the list years ago, a few 23 years ayo.

l 24 MR. McNUTT:

It's on the list.

Is that like a 25 menu of various --

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CHAIRMAN MOHSENI:

Yes, it is a menu from which

)

2 cities can choose.

They're not required to do everything on l

3 it.

In fact, we had word that not too many were opting to i

4 have KI and that's why I asked Aubrey.

l 5

MR. McNUTT:

It's still a matter of contention l

l 6

that some think it shouldn't even be on the list.

7 CHAIRMAN MOHSENI:

But it is on the list.

8 MR. GODWIN:

I'm just saying that it's there.

Be 9

aware of it.

10 CHAIRMAN MOHSENI:

Yes, yes.

11 -

MS. KEY:

Are you saying though that this list has 12 some sort of risk analysis associated with it?

13 CHAIRMAN MOHSENI:

No, no.

l l

14 MS. KEY:

You were saying that these people

,(,)

15 realized that anthrax and stuff had a higher risk.

16 CHAIRMAN MOHSENI:

No, no, they knew what they 17 were using it for.

Because of all the -- you hear in the l

18 media there's a lot of hoaxes and so forth.

None of it has 19 really pointed out the nuclear stuff.

They're mostlv -- so 20 there's much more -- yeah, they're much more sensitive about j

21 chemical and biological than they are about 22 MR. GODWIN:

There's not a formal statement but 23 intuitively you've got a lot more biologics than you do l

24 potassium.

25 MR. McNUTT:

I think the more plausible scenario

[

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would include a biologic or chemical terrorist attack.

(v) 2 CHAIRMAN MOHSENI:

Especially since Tokyo occurred 3

and it basically set the tone, yes, you're right.

4 MR. GODWIN:

Tempt Jim out further.

I don't think 5

it can be over-emphasized the importance of the PAG's that 6

come out of FDA and I guess with concurrence of EPA.

That 7

could change radically the tone of things, particularly if 8

it ends up the way the WHO.

Where you have a combination of 9

agents and doses in terms of radiation dose as well as 10 blocking doses to consider, you get into a fairly large 11 number, I think, for emergency response workers to work with 12 and none of the current experience involves anything other 13 than basically a pill that may be broken in half for certain 14 groups.

And I think to go totally on our current

()

15 experience, if something comes out from FDA and EPA like 16 that, maybe lead us down the path and we need to look at 17 that issue when it's developed very closely because when you 18 look at the WHO report you'll see the combinations you end 19 up with.

We'll talk about that Thursday.

20 MR. CARPENTIER:

There is one place that is 21 looking into implementing something like the WHO guidelines 22 and that's the Province of Quebec.

Their policy is 23 curre...

.n the works, so I can't tell you much about it, 24 but when that comes around on Wednesday, I'll tell you what 1

l 25 I know so far.

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MR. GODWIN:

But it is a complicated issue.

l ()

2 MS. CARPENTIER:

.Yes, definitely.

3 CHAIRMAN MOHSENI:

Are you suggesting that maybe 4

this group ought to, through our representatives, both EPA 5

and FDA, give them some recommendation as to why that 6

becomes complex and whether or not there's any benefit to be 7

gained by making it.as complex as it is?

Is that what 8

you're suggesting?

9 MR. GODWIN:

I would hope that whenever this 10 country guidance people come down with it, they come down 11 with a whole lot simpler program than is proposed currently 12 in the WHO.

13 CHAIRMAN MOHSENI:

And do you hope that they l

14 understand why simplicity here matters in a sense?

()

15 MR. GODWIN:

Well, I hope I can do a better job 16 explaining it to you c'l if I need to than I did the WHO, 1

17 because I lost there.

18 CHAIRMAN MOHSENI:

Okay, I think, you know, this 19 document could serve for the pros and cons of a more i

20 simpler, you know, system versus a more complex system.

If 21 there is -- if you feel strongly, Aubrey, that simplicity 22 matters, would you then offer us a paragraph or a page 23 suggesting the pros and conc?

24 MR. GODWIN:

Well,-let's see if people agree with 25 me first.

When we get there, we'll talk about it.

l l

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CHAIRMAN MOHSENI:

Okay.

1 ()

2 MR. GODWIN:

If they don't agree with me, I'm not 3

going to waste my t.ime.

I'm lazy.

4 MR. McNUTT:

We'll talk about that on Thursday.

5 MR. GODWIN:

Yeah, we'll talk about it Thursday.

6 MR. McNUTT:

They're not here now.

7 CHAIRMAN MOHSENI:

No.

Thursday is the day where 8

we have Fred Hutchinson and WHO and FDA talking a lot of 9

health effects.

'Is there anything else anybody else wants 10 to mention before we begin with Jim's presentation.

11 MR. HARDEMAN:

I figured we'd have to get around 12 to it before long, s

13 MR. GODWIN:

I tried, Jim.

14

//

15 PRESENTATION OF J. HARDEMAN, SEVERE ACCIDENTS 16 MR. HARDEMAN:

The severe accident section with 17 the exception of the discussion on Chernobyl changed very 18 little between the original new reg and what we've got now.

19 The wording is pretty well the same.

There are some pieces 20 of information that I think would be helpful in there.

You 21 know, in general terms after the Windscale accident, we've 22 heard that there -- Aubrey?

23 MR. GODWIN:

I have a problem right now with your 24 severe accidents.

The E-mail did not transmit the first two 25 pages in the context of severe accidents, so I'll pass l

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)

1 around copies of that and everybody will have it.

I hope

()

2 that's the version that's back there.

It didn't come 3

through, I don't know why.

If we all use the same version, 4

that helps.

Sorry, Jim.

5 MR. HARDEMAN:

I'm assuming that everybody has l

6 read through this.

I thought that Charlie, for the most 7

part, worked on this section and I inherited being able to i

8 talk about it.

9 MR. SHERIDAN:

Has it changed much from the 10 February 19th?

11 MR. GODWIN:

Not much.

l 12 MR. HARDEMAN:

There were some wording changes but4 l

13 I think in essence of it is pretty much the same.

It goes 14 into the history of how we got to where we are.

I think one 15 thing that if the information is available that I would like 1

16 to include in here skipping back to II D, which is on page v 17-according to the latest draft, it seems that there should be 18 some help and follow-up studies on the folks that were 19 exposed to iodine 131 from Windscale and we don't have any l

20 discussion of what happened to those folks.

21 I know the doses weren't as high as was l

22 experienced at Chernobyl or even from the Hanford releases 1

23 that we're going to talk about later in the week, but it 24 seems like that would be an important data point to me to l

25 look at.a' follow-up on the folks that got _odine 131 uptake ANN RILEY & ASSOCIATES, LTD.

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from the Windscale accident and just see what happened to

()

2 those folks.

Was there any increase on the rate of thyroid 3

disease.

There's not really a statement to that effect.

4 I know we talked about it before the meeting, Aby, 5

that in general terms there was no effect observed and I 6

think that ought to be documented in there somehow.

7 MR. GODWIN:

What about the dosimetry, do we have 8

any feel for that?

9 CHAIRMAN MOHSENI:

Yes.

10 MR. HARDEMAN:

No.

]

11 MR. GODWIN:

I don't.

{

12 MR. HARDEMAN:

I don't know, not in this --

13 CHAIRMAN MOHSENI:

Not in this document.

14 MR. GODWIN:

Not in the book, but do Brits have

)

15 dosimetry for the population?

h 16 CHAIRMAN MOHSENI:

Yes, they've made extensive j

17 sampling and there was iodine 131 in the milk.

18 MR. GODWIN:

Did they break it down by age groups 19 and all that kind of stuff?

I'm not even sure how big 20 population was exposed at this --

21 CHAIRMAN MOHSENI:

There's a document we can go 22 back to.

That's the document that Charlie was using to --

23 but the bottom line war, as Jim mentioned, that there were 24 no health effects that we are aware of as a result of that 25 release.

However, that did change our concepts in terms of i

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20 1

iodine.

That has brought the iodine on the front burner

()

2 ever since, if you will and then TMI, we said, "Well, if you 3

don't get as much iodine,-then we have to understand the 4

source term better", and that led to a revision in the 5

source term, which even today has -- as you know, the 6

fraction of iodine is still significant even in the new 7

source there.

8 MR. GODWIN:

One other comment on that section, j

9 the last sentence in it, "The facts is hard to ignore", I 10 think it should be are.

11 MR. HARDEMAN:

Well, taken.

I thought we were 12 going to have a technical writer, we can just correct all of 13 that.

14 CHAIRMAN MOHSENI:

Yeah, yeah.

Let me give you --

)

15 Ohio wrote us an E-mail and in it they said, maybe you need 16 to address this, "It is important that the KI Core Group 17 revisit the radio-iodine release duration and concentrations 18 that should be planned for if we are to provide KI to the I

19 general public.

We do not believe that the severe core 20 accident scenario is appropriate as the design basis 21 accident for KI distribution".

22 MR. HARDEMAN:

I've read that and I wasn't clear 23 on what they were saying there because to my way of thinking i

24 you've got to have severe core damage to get iodine out in 25 the first place.

So if you're not using that as a basis for Oi ANN RILEY & ASSOCIATES, LTD.

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21 l

1 your planning, then what do you use?

2 MR. GODWIN:

This goes back to the basic question 3

that is discussed extensively at 0396, the planning basis 4

for accidents and the issue is not the design based l

5 accidents.

You're going beyond the design based accident 6

and the question is how far beyond the design based 7

accidents is it practical, reasonable to make a plan for.

8 The design based accident should not cause a need to move 9

anyone or do anything.

10 Because of that, I read that, you've got to go 11 beyond the Class 8 if you would, definition and go to a 12 Class 9.

The question is, how far?

Xn 0396 they had

(

13 extensive iodine doses out in some of their postulated

]

14 accidents.

You did have dry containment or near dry 15 containment situations.

If that, indeed, is what we really

-16 need to be planning for and to extensive detail, we need to 17 say the risk clear to the public.

18 On the other hand, if we are not needing to plan 19 to that detail, then we need to quit wasting our money 20 trying to play like we're going to do it.

And that's just a 21 positive decision that's got to be made somewhere down the 22 line.

23 CHAIRMAN MOHSENI:

It is important to note that 24 when we used 1150 as the basis for source terms, what are 25 you going to get, which goes beyond design basis, obviously, ANN RILEY & ASSOCIATES, LTD.

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22 1

and in those source terms, if you recall in the original

()

2 draft new reg, the four scenarios that were used, three of 3

them had significant iodine.

One of them had insignificant 4

iodine.

In all cases we had severe core damage and TMI was 5

a severe core damage with no more than 15 calculated curies

[

6 of iodine released.

7 To get iodine out of any significant amount you 8

have to go mechanistically to damage the core significantly.

9 MR. GODWIN:

And you've got to achieve a near dry 10 core condition.

11 CHAIRMAN MOHSENI:

Yes.

12 MR. GODWIN:

Now, you get a certain amount l

13 boil-over and carry-over that could be vaporized in the 14 stain.

If the PAG's are down at one RAD's that may be

)

15 significant.

On the other hand, if they remain higher than 16 that, it may be far less significant.

17 CHAIRMAN MOHSENI:

Again, going back.to the Ohio 28 comments, Ohio has decided to use -- not to use the one rem 19 WHO recommendation but to go with the level at which we 20 evacuate the public which is five rem thyroid projected not 21 measured necessarily.

If you.can project that, if you 22 recommend evacuation then you also take KI.

23 MR. GODWIN:

Well, I would suggest to anyone that 24 we need to recognize that you can evacuate no matter what 25 the dose is projected.

If you get them out ahead of cloud, b

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23 1

you should never give.KI.

It's only if you cannot get

/ 'l 2

V somebody out of the cloud that it should be given and KI is 3

never a replacement for evacuation.

Somewhere we need to 4

come down hard on that in this document.

5 MR. HARDEMAN:

I think -- I know we discussed that j

5 in Washington, that this is a supplement.

If it's used at l

7 all, it is to be used as a supplement to evacuation and not 8

in lieu of evacuation.

I don't know whether -- I can't 9

remember whether it actually -- that statement actually made 10 it in here.

11 MR. GODWIN:

Well, you know, the Ohio comment, I'm 12 not sure that they expressed it well as to what they're 13 doing but I hope they really meant that they would give it 14 only if somebody had inhaled or ingested, presumably, the

()

15 projected dose of that, not the fact that they had a cloud 16 movement.

17 MR. SHERIDAN:

I think they made it clear in that 18 article that evacuation was primary and they did say 5 rem 19 and that makes sense to me.

20 MR. HARDEMAN:

I can't hear you.

21 MR. SHERIDAN:

Excuse me, they did say 5 rem and 22 that makes sense to me that my first comment was that they 23 made it clear in that evacuation -- I thought, let me put it 24 that way, that evacuation was the primary objective but that 25 5 rem was the measure to be used because that's when they I

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24 1

would 'nitiate evacuation and that makes sense it seems to 1 ()

2 me.

Why would you evacuate if you didn't have to?

Why 3

would you issue KI if you were below the evacuation level.

4 MS. SIMPSON:

Excuse me, are we talking about 5

issuing KI or are we talking about consuming or ingesting 6

KI?

Those are two different things.

We may issue it at one 7

point and not ingest it at all or ingest it at some other 8

point.

I have not read the Ohio paper, so I don't know.

I l

9 can see where it could be provided to them at 5 at that kind 10 of a thing, but they would be told not to take it, for 11 example, until there was, in fact, a release, until there 12 was confirmation, until whatever.

13 MR. GODWIN:

Yeah.

It was not that clear from what I recall in that paper, what they were trying to 14

()

15 convey.

That's why I made the point because I want it in 16 the record.

And I think this represents the group thinking, 17 that evacuation is the primary thing and we're not going to 18 suggest any government official to have people take KI t

19 unless they've actually received an inhalation of iodine, 20 radioactive iodine or they're going to and you know you 21 can't get them out.

Some accident is going to occur, l

22 they're on the road, you know they're going to get it, in I

23 that case give it to them in advance and they will be better i

24 off.

25 But as a practice, we should not give it unless I

O-ANN RILEY & ASSOCIATES, LTD.

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20036 (202) 842-0034 L

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there's a legitimate exposure.

[D 2

MR. HARDEMAN:

The way the Ohio comment read, and V

3 I guess it's subject to interpretation, you know, depending 4

on how lawyerly you want to be, but it looks to me in 5

looking at that they've said our intervention level for 6

thyroid prophylaxis is 5 rem CDE.

If we reach a 5 rem CDE 7

proj ection, we're going to A, evacuate and B, we're going to 8

give them KI.

And that's kind of a way of reading it.

9 CHAIRMAN MOHSENI:

Let me read what they say.

10 "Hence, the limited options dictates the ODH, Ohio 11 Department of Health, recommendation to the general public:

12 those who have KI readily available or who can get it 13 outside of the 10-mile EPZ, take it when OHD recommends 14 evacuation.

Further, any evacuees who come to a reception

()

15 center gets KI with contaminated people, pregnant women and 16 children having first priority to it".

17 So they're given to take it, they're not given to 18 say, "We'll let you know later on whether or not you should 19 take it".

The recommendation is taking it when you evacuate 20 if you have it pre-distributed and already have it.

21 Okay, but that's just a note.

Throughout the next 22 few days we're going to discuss this further.

23 MR. GODWIN:

I would still urge that eventually we 24 have some recommendation that clearly shows that evacuation l

25 is our primary issue.

I i

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26 1

MR. HARDEMAN:

Well, that was already in the 2

policy statement up front, I thought and we discussed that a 3

good bit during December.

In fact, it looks like the first 4

page got kind of even lopped off of this copy.

It kind of 5

starts off in the middle of the sentence here.

6 CHAIRMAN MOHSENI:

Let me remind you that the 7

policy statement that needs to be up front has several 8

_ things in it, I think it's emerging.

If you recall last 9

time we talked about KI is not supposed to be for ingestion 10 pathway.

It's only -- if anyone wants to consider it, it 11 should be considered for the plume phase only.

It's not an 12 acceptable practice in this country to use KI in the 13 ingestion pathway.

That's one of the issues that goes into 14 the up front policy.

15 There is no question that the up front policy 16 should also include what Aubrey just mentioned, that --

17 MR. GODWIN:

The abstract has an illusion to it 18 very clearly.

The second sentence, it's a supplemental 19 protective action.

20 MR. HARDEMAN:

Yeah, that needs to be repeated in 21 the introduction, I think.

In fact, if we're -- you know, i

22 if we're looking at this document as helping states / locals i

23 in developing or implementing a KI policy or KI -- you know, 24 whatever they want to do with regard potassium iodide, it 25 probably wouldn't be a bad idea if we repeat somewhere in ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.

20036 (202) 842-0034

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)

I 27 1

that introduction just exactly what current potassium iodide

()

2 policy is if it will stay still long enough that we can i

3 actually write it down and put it on a piece of paper.

4 CHAIRMAN MOHSENI:

Dick, I'm going to make you our 5

person to keep track of the big points and assignments given 6

out and issues that we need to resolve.

And what I write up

(

7 there later on, if you could just keep track of what we're 8

saying here, what we're claiming we'll be doing so we don't 9

-- is that okay, Dick?

Can you do that?

l 10 MR. COWLEY:

If you trust my note-taking.

11 CHAIRMAN MOHSENI:

I know I always had a hard time l

12 reading, tour handwriting but --

13 MR. COWLEY:

So do I?

I can go back and look at 14 some of the things I've sent to you over the past year or

)

15

_two, Aby, because I know personally that in some of my 16 correspondence to you that I made that point ridier 17 strongly.

18 CHAIRMAN MOHSENI:

Yes, yes.

19 MR. COWLEY:

I know New Jersey did as well in 20 their comments and I think Illinois did as well, you know, l

21 that we've got a lot of experience in evacuation, that it 22 seems to be effective and you know, protects from the whole 23 spectrum of radio-nuclides instead of just on one and so on l

24 and so forth, all of the litany of things that we talked 25 about in December.

O ANN RILEY & ASSOCIATES, LTD.

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20036 (202) 842-0034 l

F-28 1

MR. McNUTT:

What point are we trying to make

(

2 here, that evacuation is a primary protective action and l

l 3

that KI is a supplemental effective measures.

4 CHAIRMAN MOHSENI:

Yes, up front.

5 MR. McNUTT:

Well, I think we can do that.

6 CHAIRMAN MOHSENI:

Yes, it's nothing new.

We've 7

done it.

8 MR. McNUTT:

In fact, I think even the last 9

version of the participants used the word " supplemental" in 10 it, did it now?

11 CHAIRMAN MOHSENI:

Correct.

Even if FRPCC has 12 chosen the word " supplemental", so we're all talking it's a 13 supplemental protective action, not a substitute.

14 But the only thing we don't have is really that up

()

15 front policy statements that are so obvious that we don't 16 want anybody to misunderstand where we're coming from.

17 MR. HARDEMAN:

Part of that, I think, was embodied 18 in that language from New Jersey that I gave staff in the 19 December meeting and I don't know if they've incorporated it 20 in or not.

I didn't bring that language with me this time, 21 so I have to go back and resurrect that to see if I can 22 maybe see an E-mail to Joe LaPodi (ph) and get an electronic 23 copy of it.

24 But I distinctly remember that disclaimer talking about --

1 25 CHAIRMAN MOHSENI:

Right, and we adopted that in i

/\\

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our last meeting which --

()

2 MR. HARDEMAN:

And I thought it would have been in 3

here.

4 CHAIRMAN MW.SENI:

Yes.

Okay, go back to l

5 Chernobyl c. gain.

Walk us through --

1 6

MR. HARDEMAN:

Well, I didn't get through 7

Chernobyl.

I was still going through Windscale and i

8 Windscale, it's hard to really draw any conclusions from i

l 9

Windscale unless we've got the dosimetry data and unless 10 we've got the follow-up epidemiological studies on the 11 population to see, you know, where there thyroid doses that l

l 12

-- if you believe iodine 131 causes cancer er causes these 13 other thyroid abnormalities, then are there thyroid doses 14 large enough there that you would have expected to see them

()

15 in this population and did you see them in that population.

16 So we might want to go dig just a little bit more and get 17 that data.

18 TMI, probably the best thing that we get out of 19 TMI is the fact that we do have the domestic experience that 20 gives us a sharp contrast into -- basically you get a sharp 21 contrast between U.S. standard white water reactors versus 22 the graphite moderated reactors both in Windscale and later 23 on, Chernobyl.

So I think you still have to look at -- you 24 can't discount' reactor design.

I mean, we have to live with 25 the reactor design that we have in the United States and not l h ANN RILEY & ACSOCIATES, LTD.

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try to design a program around somebody else's reactor

()

2 design and try to respond to that.

3 Chernobyl --

4 MR. GODWIN:

Before you leave TMI --

5 MR. HARDEMAN:

Okay.

6 MR. GODWIN:

-- what was the highest dose to 7

thyroid projected off-site from TMI?

8 MR. HARDEMAN:

I don't recall now.

9 CHAIRMAN MOHSENI:

Projected?

You mean projected 10 or actually measured at some point, calculated.

11 MR. GODWIN:

Well, what they projected and then my 12 next question was going to be what did they actually 13 measure.

14 MR. HARDEMAN:

Well, I don't think they measured, 15 except for making extrapolations of what environment site 16 there were, what they had in milk and so on and so forth.

I 17 don't think there was actually --

18 MR. GODWIN:

Did anybody ever come up with air 19 inhalation dose for any age group at all around there?

20 CHAIRMAN MOHSENI:

The calculated dosage for --

21 overall, the total doses did not exceed several milli-rem.

22 MR. McNUTT:

About 70 to 100 milli-rem.

23 CHAIRMAN MOHSENI:

Yeah.

24 MR. McNUTT:

That's whole body dose.

25 MR. GODWIN:

Was that projected or was that actual t

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measurement.

()

2 MR. McNUTT:

That was estimated off-site dose

)

3 based upon the, I guess, combination of TLD's and 4

environmental samples as I recall.

5 MR. HARDEMAN:

We?'., how did that compare to their 6

dose projections during those -- you know, contemporary dose 7

projections?

8 MR. GODWIN:

There wasn't a whole lot of dose 9

projections done as I recall.

10 MR. McNUTT:

Wasn't that the problem tb<,

11 projections, whether they were dose or hydrogen bubbles, 12 were a little bit off the mark to begin with and that's what 13 caused a lot of the furor?

So I don't think you want to go 14 too far with projections.

I mean, you can project almcst

.r(

15 anything.

16 CHAIRMAN MOHSENI:

Especially with the knowledge 17 at the time that they were not aware that they had damaged 18 the core and so any projections --

19 MR. NAWOJ:

Well, thTr projected that, too, there 20 was little or no core damage.

21 CHAIRMAN MOHSENI:

Yeah.

22 MR. GODWIN:

Well, the thing that keyed everything 23 was when they made the measurement down the smoke stack in a 24 1,000 or so milli-rem.

Unfortunately it was looking at the 25 whole column in the stack, a little minor detas' there, and O

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32 1

then -- but backing into it, I would have thought somebody

()

2 would have made some back calculation of iodine dose from 3

any iodines they found.

They did find some iodines in the 4

environment as I recall.

l l

5 CHAIRMAN MOHSENI:

And that's how they back 6

calculated.

7 MR. GODWIN:

And as I recall, milk was on the 8

order of 20 to 30 PD curies per liter and --

l 9

MR. HARDEMAN:

Is there any of that in new reg 10 1251?

11 MR. GODWIN:

That would back calculate the list in 12 milli-rem.

13 CHAIRMAN MOHSENI:

Yeah, we have that.

I just 14 don't remember it off the top of my head.

That's -- do we

()

15 need that?

16 MR. HARDEMAN:

No, but it would be a good data 17 point that we could clarify, you know, show in here that the 18 dose was very low there, it wasn't worth the effort.

That 19 would be a good point to have in there.

20 CHAIRMAN MOHSENI:

To do what again?

21 MR. HARDEMAN:

In other words, it would be a good 22 point to say this was the'most severe accident that we've 23 had in the United States for a commercial reactor.

Thirty 24 percent of the core went phht.

How you're going to spell 25 that, I don't know, and then -- and yet you have virtually i

i O

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33 1

no iodine release.., containment did what it was supposed to 2

do --

3 MR. GODWIN:

And the dose was --

4 MR. HARDEMAN:

-- and the dose was minimal.

5 MS. CARPENTIER:

Then you wouldn't want to give 6

those people iodine.

7 MR. GODWIN:

Heavens, no, there's no where near --

8 but just something so that people can get a reference to.

9 10 MR. HARDEMAN:

But think about it now, in today's 11 environment, the way we do business now where we're making 12 protection action decisions based on plant status, as 13 opposed to waiting and projecting a dose and doing all of 14 this stuff, looking back 20/20 hindsight, if you had known

()

15 what was happening --

16 CHAumiAN MOHSENI:

We have that.

17 MR. HARDEMAM:

-- we would have ev9eaated people.

18 CHAIRMAN MOHSENI:

Yeah, okay.

19 MR. HARDEMAN:

And then under some of these 20 policies, it looks like you might have actually given them 21 KI, too.

22 CHAIRMAN MOHSENI:

A major core melt was 23 experienced.

Millions of curies of notable gases were 24 released to the environment but tne iodine release was l

25

trivial, i

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1.

MR. HARDEMAN:

Right.

2 CHAIRMAN MOHSENI:

In fact, we can elaborate on 3

that saying it was -- it's all in there.

l 4

MR. GODWIN:

Yeah, I agree, but I'm just saying --

1 l

5 CHAIRMAN MOHSENI:

It even gives you that maximum 6

dose of 75 milli-rem to the highest level, highest 7

individual guide off-site.

It's there.

I don't know in how 8

many different ways you want to say that.

It's there.

You 9

can highlight it even more.

10 MR. SIMPSON:

But I think maybe Jim's point was 11 more -- and I don't know whether we're in the business of 12 making conclusions but his point was the conclusion of that 13 is the dumb old concrete and rebar did its job no matter 14 what the stupid human beings tried to so.

O 15 MR. HARDEMAN:

That's pretty well put Andy.

16 MR. GODWIN:

I think that the reader needs to get 17 a feel he's trying to make a decision whether to go with it.

18 He's getting all these pressures of people say, " Yeah, 19 you've got to go with it",

at least get a feel for what the 20 U.S. experience is and how it really translates in 21 dosage-wise, so that he can say, "This is the worse accident 22 we had and it didn't do this.

You want to crank up a $2 23 billion program to put this stuff out that's probably not 24 going to be very useful.

25 Where another guy say, "Okay, it's only going to f

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cost me $5,000.00 to do it.

I'll do it anyway".

You know,

()

2 looking at the different scenarios around different plants, 3

is going to make a lot of difference in the way the decision 4

maker is going to be able to have it.

5 CHAIRMAN MOHSENI:

Yeah, I think the way the 6..

report is structured, you don't want to put that conclusion 4

7 under TMI.

You want to say, "Here's what happened at TMI".

8 MR. GODWIN:

No, no, I just want the basic data 9

from TMI.

10 CHAIRMAN MOHSENI:

Yes, yes.

11 MR. GODWIN:

He can draw his own conclusions from 12 it.

13 CHAIRMAN MOHSENI:

Yes, yes.

We got SL 1, we got 14 Windscale, we got Three Mile Island, we've got Chernobyl,

)

15 we've got the Hanford release and --

16 MR. HARDEMAN:

Which they're calling that an 17 accident --

18 MR. GODWIN:

Hanford, I'm not sure -- I've got a 19 problem believing that meets our criteria.

20 CHAIRMAN MOHSENI:

But let me finish ny sentence 21 here.

You've got all these events where environmental 22 releases have or could have occurred, protective actions 23 could have been taken.

If we knew of them occurring today, 24 we'd probably take protective actions with the quantities l

25 they're telling us.

And we can now put the entire results l

i

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in maybe a table, so that the reader says, "Okay, here's the

()

2 historic. experiences we've had.

This is the amount of 3

releases and these are potential doses that -- you know, 4

range of doses, obviously, you don't have any single doses, 5

range of doses from these events and to draw your own 6

conclusion you're saying.

7 MR. SHERIDAN:

Can I ask a question here?

Have we 8

given and thought to putting in what individual -- each 9

individual response, not personal but community response was 10 to each one of those incidents?

For example, Three Mile 11 Island, was there an attempt to locate sufficient KI and if 12 there was, how long did it take and was there sufficient 13 quantity?

Those would be the questions that I think are 14 more pertinent than what we're trying to do and it's very 15 important, it's been very educational for me to look at the 16 experiences evolved over the last few weeks.

17 But I keep asking myself if one of the millstone 18 plants has a problem, can we put our hand on sufficient KI, 19 can we get it there on time and can we get enough of it?

z 20 CHAIRMAN MOHSENI:

Regardless of whether or not 21 this will get to the point where you would actually need it.

l 22 MR. SHERIDAN:

Exactly, thank you.

That's the i

23 main part of my point.

24 CHAIRMAN MOHSENI:

It is a -- okay, these are 25 valid questions.

These are planners who are looking at, f.)

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with or without specific knowledge of whether or not in this

()

2 specific scenario is useful or not, do I have knowledge of l

3 where KI is located.

Now, that's where the NBC stockpile 4

would come in handy.

If you knew the nearest city had KI.

5 MR. GODWIN:

Go to the Navy.

Talk to the 6

President and go to the Navy.

7 MR. NAWOJ:

Can I say something?

8 CHAIRMAN MOHSENI:

But that's only -- yes, or 9

course, but that's only to address --

10 MR. NAWOJ:

Here, you've got the core group here 11 and it's kind of structured with NRC, FEMA, FDA and EPA and 12 those states that have -- that are distributing KI to the 13 general public.

Okay.

14 CHAIRMAN MOHSENI:

And one that's not.

15 MR. HARDEMAN:

Connecticut is and CRCPD and NEMA.

16 MR. NAWOJ:

But it sounds like we're considering 17 KI for the public for the first time.

Let me point out that 18 there are a number of other states that have considered KI 19 and thought better of it and there are more of them than 20 there are that have thought better of it.

And if you look 21 at those states' experiences, their numbers are -- you know, 22 you can put a couple thousand pills in a cookie jar here or 23 candy jar, and you've got your plan implemented.

24 In the other states where they've thought better 25 of it, you need a lot more cookie jars.

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38 1

MS. PEPPER:

The phrase stacking the deck has

()

2 occurred in some places as to why this group was structured 3

the way it was.

Thank you, Mike, for bringing that up as to i

4 why --

5 MR. NAWOJ:

We have considered KI in significant l

6 detail and this is kind of deja vu sitting here, going over 7

these scenarios and the results and where you're going to 8

get it and so, you know, we're re-inventing another wheel 9

MR. GODWIN:

There's a slight deviation into play.

10 First of all, there is another state, Georgia does not, so 11 they're not one of them.

12 MR. HARDEMAN:

Not to mention that I'm supposed to 13 be wearing the hats for all of the other states that don't 14 approve or didn't approve.

()

15 MR. GODWIN:

The problem is not so much the basic 16 issue if KI as the fact that there may be a major change in 17 the guidance.

You can make an argument when most of the I

(

18 states were considering it, that at 25 RAD's there are darn 19 few scenarios that you can screen out that's going to get 25 20 RAD's out airborne.

21' MR. NAWOJ:

Then we get to the issue of is that 24 22 RAD projected or is it measured and if it's measured, you're i

I 23 too late and if it's projected you may be wrong by seven or l

24 eight orders of magnitude.

25 MR. HARDEMAN:

In either direction.

1 l

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39 1

MR. NAWOJ:

There are very few scenarios you can

()

2 realistically get a dose out that will give 25 RAD's to be 3

considered.

Therefore, many states looked at it and said, 4

"Those accidents are beyond where we want to plan for".

If 5

it gets brought down to one RAD, as suggested by WHO, there 1

6 are more scenarios, the states really need to take another i

7 look at it.

There's also been another generation of people 8

in decision making positions.

You almost have to re-educate 9

the whole problem all over again.

10 MS. KEY:

I'd also like to say, I mean, I come 11 from a state that pre-distributes.

That doesn't mean that 12 the things I'm going to tell you about our experience with 13 it are going to be positive toward pre-distribution.

14 MR. HARDEMAN:

And that was one of the things --

15 and I have to take at least partial responsibility for being 16 constituted the way it is because when Aby and I talked 17 about this very early, when the concept of KI Core Group was 18 just in its infancy, I told him that we needed to -- you 19 know, we needed the states that have experience with KI 20 programs to sit around the table and tell us the pros and 21 cons of their experiences.

So --

22 MR. NAWOJ:

Very true.

And just because a state 23 has a policy that says it will not distribute KI to the j

1 24 general public, that should not be construed to mean that 25 the general public cannot have KI.

It's just that I, as a

()

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Wash;' gton, D.C.

20036 (202) 842-0034

1 40 1

state official, am not going to stand there and say, "Here's

[

}

2 yours, here's yours, here's yours".

They need -- the 3

general public needs another pathway perhaps to get at it.

4 I think most states have --

5 MR. SHERIDAN:

I don't know what you mean by that 6

because in Connecticut I would like to have KI in Waterford, 7

but I can't until the State of Connecticut says it's fine to 8

have it.

9 MR. NAWOJ:

I'm not sure that's so.

I think --

10 MR. SHERIDAN:

Well, I'm certainly not a 11 pharmacist and I don't have the --

12 MR. NAWOJ:

You can go down to Osco and if Osco is 13 willing to carry it, then any of your residents can go in 14 there and buy as much as they want along with their

()

15 Iburprofen.

16 MR. SHERIDAN:

That's not true, not the pharmacies 17 in southeastern Connecticut.

18 MR. NAWOJ:

Well, I understand they don't have it.

19 MR. SHERIDAN:

Nor will they buy it, nor can they 20 buy it.

21 MR. NAWOJ:

Im not sure that's correct.

22 MR. SHERIDAN:

They can buy the liquid form but 23 they cannot buy the pill form.

24 MR. NAWOJ:

I believe that there's no prohibition 25 to it.

f ANN RILEY & ASSOCIATES, LTD.

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I 41 1

MR. SHERIDAN:

Legally, then they can but there

! ()

2 may be -- the manufacturer may have policies.

3 MR. NAWOJ:

I believe you've hit that nail right 4

on the head.

And maybe that's where we ought to be going 5

with this, if we're really concerned about the public having 6

KI, cross that bridge and then the states' policies sort of 7

become moot.

And it also takes care of the stockpiling 8

issue.

Everybody will be part of the terrorist program 9

because they can carry their own KI around in their pockets.

10 MR. GODWIN:

I think the group has already agreed 11 in concept that the state will be the one who makes the 12 decision and nothing in this document will be decision 13 driving.

14 MR. NAWOJ:

Well, I'm not talking about the

()

li decision.

I'm talking about who has it.

When to take it is

". 6 something again, quite different.

17 MR. GODWIN:

Well, I'm talking about all the 18 distribution measures will be a state decision.

19 MR. HARDEMAN:

Up to the state.

20 MR. GODWIN:

Plus the decision to distribute it 21 and how it's distributed will be a state or local government 22 decision, not a national decision.

This is only to help 23 them make the decisions on their own.

24 MR. HARDEMAN:

And how the decision is made to 25 actually recommend that it be administered, not only just i

f

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20036 (202) 842-0034 1

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42 ]

1 how does it get into people's hands but how do you tell them

()

2 that they need to take it, if they need to take it.

3 MR. SHERIDAN:

That's a very important point.

We 4

are an entity of the state of Connecticut and we cannot have 5

it available unless the state authorizes it and approves it i

6 and creates the rules.

7 MR. McNUTT:

If I may, Aby.

l 8

CHAIRMAN MOHSENI:

Yes.

9 MR. McNUTT:

This -- I mean, I'm a little bit 10 confused.

We're trying to, I thought, you know, do l

11 something, make some kind of determinations on the type of 12 accidents and the severity of such that might have a release 13 of radio-iodine and we seem to be getting off into what I 14 thought we ought to be talking about later in the week.

h 15 I mean, it's frustrating to me because I don't 16 think we're getting done what we should be getting done.

17 CHAIRMAN MOHSENI:

Let's deal -- I know that as we 18 talk, anybody who says anything, it's very tempting to come 19 up with the next step and we all have issues in our minds 20 and so forth.

Let's stick to the source term issue of all 21 the accidents we've had and get the universe of information 22 in front of us.

Let's proceed back to where we are.

23 MR. HARDEMAN:

Okay, were we finished with TMI?

24 MR. SHERIDAN:

Does anyone have an answer to the 25 question I asked?

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20036 (202) 842-0034

43 1

MR. HARDEMAN:

Which is?

()

2 MR. SHERIDAN:

Does anyone have a response, what 3

was the response, was there KI available?

4 MR. SIMPSON:

There was an effort to secure KI.

5 CHAIRMAN MOHSENI:

So what you're suggesting is to 6

be added to the --

7 MR. GODWIN:

Let Pennsylvania answer that because 8

they're the ones who had the incident.

9 MR. SIMPSON:

Yeah, there was, and I don't 10 remember all the details.

I wasn't there at the time, thank 11 goodness, I was in Europe.

I'm glad I didn't have to put up 12 with that nonsense.

There was an effort te obtain KI.

They 13 went out, they sought manufacturers.

They were seeking if I 14 recall and don't quote me for sure, something li.ke 300,000 s,/

15 doses.

It was not available.

They did emergency 16 manufacturing and I don't remember the time frame but it got 17 there, days, weeks, later, not in any time it would have 18 been efficacious had it been needed which it turned out not 19 to be needed anyway.

20 MS. PEPPER:

And it broke down quickly if I 21 remember because the supply wasn't stable.

It didn't last a 22 long time.

23 MR. SIMPSON:

Right, it was produced very rapidly l

24 and it was not very good.

25 MR. SHERIDAN:

Then the next logical question it O

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20036 (202) 842-0034

44 1

would seem to me, should that comment be part of this 2

document?

3 MR. JAMGOCHIAN:

Can I say something on that?

4 Mike Jamgochian from the NRC.

The bottom line on the TMI 5

accident is there was a Kennedy commission that was formed 6

after TMI that looked at all of the pluses and all of the 7

negatives as a result of THI, all of the things that were 8

done right and done wrong.

And one of the primary 9

recommendatione of the Kennedy Commission was that KI should 10 be stockpiled around nuclear power plants for the general 11 public.

12 MR. HARDEMAN:

Exactly.

13 MR. JAMGOCHIAN:

So that's the bottom line and in 14 fact, the petitioner who started all of this used that as a 15 fundamental basis for his petition.

16 MR. SHERIDAN:

That clarifies my point and I thank 17 you for that because that's an important point.

So now the 18 next logical question, the document I think should say 19 exactly what this gentleman just said, Mike?

20 MR. JAMGOCHIAN:

Mike, Mike Jamgochian.

21 MR. SHERIDAN:

And then the next question I would 22 want to have the document address is, is it presently 23 available?

If that commission suggested that it be 24 available, is it presently available around nuclear power 25 plants?

f

[~)

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1 MR. HARDEMAN:

I think the Kennedy commission

(

2 suggested that KI should be available.

I don't think it 3

went as far as to say for ti.

general public.

It said KI 4

should im = Je available and that it has some use.

That use 5

has been subsequently reviewed by a n mber of states and

)

6 they found that, yes, for emergency workers and for 7

institutionalized individuals KI is appropriate.

With l

8 respect to the general public, that seems to be what is at 9

issue now.

10 MR. McNUTT:

The Kennedy recommended it for the

)

l 11 general public, have it available to the general public.

1 l

12 MR. JAMGOCHIAN:

The Kennedy Commission did 13 recommend stockpiling for the general public.

They did not

)

14 want to go through another TMI where all of a sudden late at 15 night we're looking for pharmaceutical houses to manufacture 16 this stuff.

The bottom line was the NRC at that time, in J

17 1983 and '84, was about to recommend stockpiling for the 18 general public.

19 In 1985 that position switched and a 20 recommendation was made to FEMA and the FRPCC to come out 21 with a policy statement that KI should be stockpiled for 22 emergency workers and institutionali'ed people, not the 23 general public.

So there's a significant switch but the 24 Kennedy commission came out and suggested that stockpiling 25 be made around nuclear power plants for the general public.

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MR. McNUTT:

As a matter of fact FEMA back in the 2

early '80's, we actually had it in our budget and was 3

planning on buying a supply and stockpiling it.

We hadn't l

4 decided just were and at the time the first FRPCC l

5 subcommittee on KI, both NRC and FEMA altered their 6

positions and that committee came up with the policy which 7

we still have that it's for emergency workers and 8

institutionalized people.

And if the general public -is to 9

get it, it's up to the discretion of each state and that's 10 where we are today.

11 CHAIRMAN MOHSENI:

And, you know, to some extent, l

12 you go back and today many states have more information at 13 their hands than Kennedy commission had then and today when 14 they go back, they don't necessarily come up with the same 15 conclusions that historically was recommended.

Yes.

16 MR. GODWIN:

There was also an issue that got 17 involved at that time with Doctor Yamo, Yawoh, a Nobel prize g

18 winner and all that stuff, petitioned strong to stop the 19 distribution on the grounds it was a severe risk to the 20 population and many public health officials got concerned of 21 the controversy and they backed away from it at that point.

22 So there's a lot of history in there.

23 I cion' t know that -- I would be surprised if very l

24 many states will change their positions as a result of the 25 document.

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47 1

CHAIRMAN MOHSENI:

Today?

()

_2 MR. GODWIN:

Yeah, today but I think that they 3

ought to have the benefit of making the decision based upon the latest information and that's what I think we're trying 4

l 5

to do.

If I'm wrong --

6 CHAIRMAN MOHSENI:

So what Tony is asking from a l

l 7

historical perspective, he wants to know what the decision 8

makers were faced with at the time, not that today they 9

would -- you would be able to repeat that scenario any more 10 than we are going to repeat the scenario of how we responded 11 to TMI, you know, in the technical world as well.

Things 12 have changed.

Our knowledge base has changed but at the 13 same time, it is a historical lesson that we don't want to 14 lose.

(

l 15 It's valuable.

We want to keep it so the decision 16 makers are aware of what pressures they face at the time and 17 whether or not, even if KI was not needed, the fact that 18 these people were searching and not knowing whether or not 19 they're going to find enough KI -- did some come from 20 Canada, I understand?

A Canadian company manufactured some 1

21 and --

22 MR. GODWIN:

Carter Wallace did it.

23 MR. McNUTT:

My concern is what precipitated the 24 demand and where did the demand come from?

Did the demand 25 come from the general public, did it come from the decision O

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makers?

I mean, all of a sudden we need 300,000 doses of

()

2 KI.

What prompted that?

3 MS. PEPPER:

It's in the Rogavin

(; h) report, p

4 which.nobody has.

5 MR. McNUTT:

Subsequently, two days later what 6

prompted them to decide they didn't need to distribute it.

7 MR. SHERIDAN:

This debate reminds me of sort of 8

having a debate about whether you should have a fire hydrant 9

in your -- at the corner of your school or a fire 10 extinguisher in your house.

It seems to me that the kind of 11 information that the past experience here is terribly 12 important because if it wasn't available, and if it isn't 13 available today, at least the document should address that 14 at the very minimum, whether the state decides to make it 15 available or not.

16 I have a very difficult time responding to my j

l 17 citizens who say, "How come we don't have it available.

You i

18 know we have fire extinguishers.

19 MR. NAWOJ:

But do you have the fire extinguishers j

20 and do you distribute them and do you recharge them and 21 check for them periodically?

22 MR. SHERIDAN:

We do better than that, we make 23 sure they're in every position that they're required.

24 MR. McNUTT:

Private residences?

25 MR. SHERIDAN:

Not private residents.

We're l

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49 1

talking about every business.

But the point is the same, 2

the point'is either we have a responsibility for public 3

health and safety or we den't and there's no half measure 4

and for -- there are about 10,000 children in the three 5

towns that encompass Waterford, two towns, New London and 6

East Line and for $22,500.00 we could have enough for every 7

child in every school there.

8 CHAIRMAN MOHSENI:

It begs the question, why don't 9

you have it already.

{

10 MR. SHERIDAN:

I know, I don't mean to belabor the 11 point here.

I 12 CHAIRMAN MOHSENI:

No, no, it's --

13 MR. SHERIDAN:

My God, it's like, you know, what's 14 the matter with this debate?

What's going on here?

15 MS. PEPPER:

Well, there's the issue of 16 information and you, as a decision maker, if there's an 17 accident at the Waterford plant today, you, as a decision

-18 maker will' have an entirely different amount of information 19 and quality of information than the decision makers had at 20 TMI --

21 MR. SHERIDAN:

Absolutely.

22 MS PEPPER:

-- which makes some of what happened 23 at TMI not terribly relevant to today, because it's not 24 going to happen the same way.

25 MR. SHERIDAN:

Understand, but you know --

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50 1

MS. PEPPER:

And that point maybe needs to be

'2 made.

3 MR. SHERIDAN:

A perfectly good point, but in 4,

those days you might be able to make a phone call and get 5

someone at the end of the line.

Now, you get phone mail and j

6 you might not reach the person you want to reach for a half 7

a day or for several hours at least.

It's much more 8.

complicated -- a much more complicated system and we have a 9

much larger population.

l 10 And what we're talking about here, I think it's 11 non-debatable, quote frankly.

The genie is out of the 12 bottle here.

KI is just one other part of our emergency 13 planning.

It should be here.

It should be available and l

14 we're making too much -- we're making a mountain out of a 15 mole hill here.

16 MS. SIMPSON:

Except the NRC has charged this 17 committee with doing just that.

It has not made the 18 presumption that KI is required, essential or necessary.

19 CHAIRMAN MOHSENI:

Neither has FRPCC for that 20 matter.

21 MR. McNUTT:

And that brings us back to my point, 22 that I think Aubrey and Andrea and Jim and you, Aby, and 23 anyone else that was a health physicist or nuclear physicist 24 or nuclear engineer, you know, put in this paper what kind j

25 of accident sequences are going to result in radio-iodine.

1 l

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MR. HARDEMAN:

I just had an idea sitting here.

I

()

2 was thinking back to all of these nice little flow charts 3

that are at RTM and I know they come up with numbers but --

l 4.

A VOICE:

What's RTM?

5 MR. HARDEMAN:

Reactor Technical Manual, I'm 6

sorry.

It's a training tool and also a response tool.

It's 7

a paper response tool that NRC brings with them when they 8

respond and they also train the state folks and local folks l

9 in the use of this.

And there are -- depending on reactor 10 design, there are a number of decision trees that say, 11

Okay, you start with this set of conditions and this 12 happens, that happens, the other happens and you follow it 13 down through.

And at the end it gives you order of 14 magnitude at best estimates of what the off-site

?

(~)%

\\

(_

15 consequences are.

16 And when those are -- as I understand it, when 17 they're presented to NRC management, they're not presented I

18 as numerical estimates.

They're simply presented as I guess 19 qualitative descriptions of the effects.

It seems to me 20 that it might be possible to look back at RTM and look at 21 those branches and see if we can re-identify which one of 22 those branches would lead us to massive thyroid doses 23 off-site.

24 MR. GODWIN:

That was one of the things I was 25 looking at.

EAL is where that comes from.

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MR. HARDEMAN:

What I'm talking about is a little

()

2 bit more general EAL's.

It's simply looking at broad plant 3

characteristics.

Then you go back into what EAL got me 4

here.

5 CHAIRMAN MOHSENI:

In fact, going back to what you 6

and Bill McNutt just requested, in the original draft new 7

reg if you recall, we went to --

B MR. HARDEMAN:

They have a description of that 9

accidents.

10 CHAIRMAN MOHSENI:

-- we went to new reg 1150, 11 pulled out one of the five plants, Surrey, pulled ouc the 12 accidents that result in iodine release and a comment that L

13 we got back from Ohio, a criticism for this was that you 14 chose the scenarios that had too much iodine.

Well, you

()

15 either get iodine or you don't get iodine.

TMI you didn't 16 get any iodine out.

But if the containment had breached, it 17 was much more than just a little bit here, a little bit 18 there.

It was like, you know, looking at it 19 probablistically the way 1150 has looked at it, we offered 20 most of the events that don't result in severe core damage, l

21 are.not going to produce the iodine releases for which KI l

22 can be measured as an ef fective p:rotective action.

23 And those that do, are necessarily involving the l

l 24 significant core damage and therefore, it has to be a severe 25 core damage not a design basis sort of type.

And to do that O-ANN RILEY & ASSOCIATES, LTD.

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53 1

you either have effective removal, in containment removal 2

processes such as sprays' filtration and plating out and 3

containment holds and as you can see TMI case in point, or 4

if it catastrophically fails the probability whether or not 5

it's more than 10 percent get out, versus -- actually 1150 6

shows that the probability is a straight line for various 7

fractions of iodine releasing, so you might as well assume 8

the worst case because they have more or less the same l

9 probability once you have the containment failure and so 10 forth.

11 And in that respect, we use the scenarios in our 1

12 draft new reg that showed where the -- what degrees of --

13 what fractions of iodines you release directly out of 1150, 14 the best document today we have in looking probablistically 15 at what happens in reactor accidents.

And in those 16 accidents, it was shown that either you didn't have l

17 anything, containment held, sprays worked, TMI case in 18 point; or all hell broke loose that you'd better evacuate.

l 19 It wasn't -- you didn't have this --

l 20 MR. McNUTT:

Nothing in between.

21 CHAIRMAN MOHSENI:

Not in these scenarios that we 22 looked at and it is likely that one could in the future come 23 up with scenarios in between but when they characterize them 24 the way they have in 1150 which was not intended for KI 25 policy making.

It was intended to understand ANN RILEY & ASSOCIATES, LTD.

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54 1

vulnerabilities of reactor accidents so that you can do --

()

2 spend your money in the right place to reduce risk.

Indeed 3

the source terms we have looked at, it's like either you 4

don't have anything, even with a severe core damage, or you 5

have a lot.

6 And when you have a lot, KI is not enough.

When 7

you don't have anything, KI is too much.

You know, so that 8

was the issue that we ad_ressed in terms of where do you 9

benefit.

It's very important because it's one thing to know 10 you have KI, I agree, but as a decision maker you need to 11 KI.

Then he will turn to public health officials, say, 12 "Okay, is this the scenario ~I need to use it, right now?

13 You know, tell me which scenario I can use it for".

And 14 that's the hard part, because when you look at the scenarios

()

15 to see what scenario you can actaally give out and benefit j

16 from other than the fact that you can't evacuate and 17 everybody has it in their homes and, you know, people cannot 18 evacuate, it's better to have KI than not to have KI which 19 has been offered.

20 But those are the things that we are grappling 21 with.

We are not -- you know, technical staff, not the 22 decision making political side.

But even getting the 23 technical black and white is noc easy.

So I think when you 24 heard that back in '80, early '80's they decided not to have 25 KI, I wasn't there then, but I can understand a little bit l (}

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20036 (202) 842-0034

55 1

here that it's not an easy decision to go with one way or

()

2 the other.

That's why the pros and cons have to be written, 3

put in front of decision makers, let them pick and live with 4

the consequences.

5 We're not going to tell, "Yes, we recommend that 6

everybody store KI".

We're not going to say that.

It's up 7

to the states.

It's a federal policy.

NRC made that 8

decision at the higher level, saying it is up to the state 9

to decide.

The pros and cons we're going to put together in 10 front and it's not going to be an easy decision.

You guys 11 have to live with the consequences of your decisions.

12 MS. PEPPER:

But a couple of things, and one thing i

13 I think Mike was driving at is that many of the states have 14 looked at use of KI and made a decision not to give it to

()

(,f 15 the public but not based on, "Oh, we're never going to get 16 to 25 RAD and yeah, we need all the most recent technical 17 information but whether it's 25 RAD or 5, it's still 18 considered unwise by people who thought it through and 19 decided they don't want to have wholesale distribution of 20 drugs and so on and so on and so on.

So it's not 21 necessarily -- just because a state decided not to do it 22 doesn't mean that they didn't go through all this process 23 and it doesn't mean that oh, just because they think 25 RAD 24 is too high, well, if they lower it, they aren't necessarily l

25 going to change their decision.

That's the one point and --

t O-ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 t

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56 1

MR. GODWIN:

Well, I thought I said that.

2 MS. PEPPER:

Okay.

l 3

MR. GODWIN:

I said I doubt there would be very

)

4 many changing their mind.

5' MS. PEPPER:

Right.

6 MR. HARDEMAN:

A lot of this was already discussed 7

and I went out and, you know, solicited the states for our 8

last meeting to try to get some input back and got very 9

little input back in some states, Illinois for an example.

l 10 There was a very clear trail of, "Here's how we reach this 11 decision and here's the decision and here's where it's 12 documented in our state plan".

And ours in Georgia, there's 13 simply no reference to making KI available to members of the 14 general public and that decision was made before my tenure 15 with the state of Georgia and there is not a decision trail, 16 at least not one that I can find to document that.

So 17 there's a mixed bag.

18 MR. GODWIN:

There are other issues also that get 19 involved in that there's a lot more known about the side 20 effects now than there was at the time of the decision but I 21 still don't think there will be that many changing.

22 MS. PEPPER:

And the other thing is, I'm really 23 going to open a can of worms.

I can just set it there and 24 drop it and we can to on to something else but the way that 25 this has been presented to the public, the way that the ANN RILEY &

o80CIATES, LTD.

d Court 2eporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I; 57 public has perceived this whole thing it's not like only NRC 1

(')

2 is studying this and going to do the pros and cons.

It's l

3

like, "Oh, the NRC is offering the states free magic 4

radiation pills".

And Illinois had to explain to the 5

Chicaoo Sun Times why we were turning down the fed's offer 6

of. free magic radiation pills.

7 MR. McNUTT:

Free magic radiation pills, I've got 8

to write that down.

9 CHAIRMAN MOHSENI:

Also remember that's another 10 effort that, you know, FRPCC and NRC are trying to kind of I

11

-- all the federal agencies, including EPA and FDA trying to 12 put out that policy that everybody has heard about but it 13 hsn't ever been finalized yet and we'll hear from F2MA 14 later on where we stand with FRPCC on finalizing that-()

15 position.

We're in the midst of it.

16 But this document is really going to be the 17 document that if the states wanted to make a very formal and 18 intelligent decision based on what everybody knows in the 19 country, supposedly this references those documents that are 20 out there that you guys can use in making that 21 determination.

The pros and cons we discussed *.st time, 22 Andrea, the --

23 MS, PEPPER:

I know and I'm sorry I wasn't here.

24 CHAIRMAN MOHSENI:

-- pros and cons of whether or 25 not the state goes with or not goes with it and I think to r

O ANN RILEY & ASSOCIATES, LTD.

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58 1

some extent we got Aubrey and I think Bill McNutt and Jim in

/~%

t j 2

some ways to put language together that shows the pros and v

i 3

cons of not having KI and then pros and cons of having KI, 4

and then once you agree to have XI, the pros and cons of 1

5 different distribution mechanisms.

6 I think this is what this document will have in 7

front of you and it won't -- in my opinion, I won't be 8

biased against one way versus another.

It will say, "This 9

is the experience, this is what everybody has said," but I'm 10 sure people will see hidden agendas everywhere.

Every word 11 will be used like --

12 MR. HAR"EMAN:

If you use that as the guidance for 13 whether you had a good document or not, then the original 14 was pretty good, because everybody was upset about one (3

(_,/

15 extent or the other.

16 CHAIRMAN MOHSENI:

Well, the previous document did 17 not have the U.S.

experience in it.

18 MR. HARDEMAN:

This is true.

19 CHAIRMAN MOHSENI:

So there is no question that 20 the U.S. experience is very valuable to a future decision 21 maker who wants to actually say, "Do I need KI or not?

What 22 do the three states that have KI have to say on that?"

So 23 that's useful.

Back to you again.

24 MR. HARDEMAN:

Okay, back to me again.

Are we 25 through with TMI now?

Are we through with TMI now?

Did we

(

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g 59 1

bury that one?

I

-(g}

2 CHAIRMAN MOHSENI:

Yes.

Two things came out so 3

far.

Windscale, when you talk about Windscale, we need the 4

health consequences and the dosimetry to the extent that 5

it's available.

6 MR. HARDEMAN:

I think it would be helpful.

7 CHAIRMAN MOHSENI:

Okay, and on TMI we're going to 8

get the experience of responder, including why they were 9

thinking that they need KI and what was it that actually 10 told them that they don't want to distribute KI.

11 MR. HARDEMAN:

And then what experiences they had 12 in actually trying to procure it and so on and so forth.

13 CHAIRMAN MOHSENI:

Okay, you know, we're capturing 14 that, Dick, but we haven't assigned it yet to anyone but

)

15 it's just activities that we need to do.

16 MR. CONLEY:

Do you want me to write that down?

17 CHAIRMAN MOHSENI:

Yeah, please, both the 18 Windscale and TMI, two action items, one on each.

19 MR. McNUIT:

I'm just wonde, ring if it's time to j

20 take a break for two minutes.

21 CHAIRMAN MOHSENI:

Okay.

Let's have a five-minute 22 break, okay, 15.

23

[ Recess.)

24 CHAIRMAN MOHSENI:

On the record.

Okay, Jim's 25 presentation.

O n

k._s/

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MR. HARDEMAN:

Okay.

Are we ready now, are we

'N l

2 ready finally to move nnto Chernobyl?

3 MR. GODWIN:

I'm ready.

4 MR. HARDEMAN:

Okay, let's move onto Chernobyl.

5 There are two sections in the draft that deal with 6

Chernobyl; basically one saying what happened which is one 7

that Charlie, I think, authored and then a second section 8

that deals with implications or at least my view of what the 9

implications of the Chernobyl accident were for the U.S.

10 The first section there was a general statement, I 11 think we probably, going back to your comment earlier, Aby, 12-about there being a table, I don't really know how you would 13 boil Chernobyl down to a couple entries in a table.

You 14 might could say, "Well, you know the radio-iodine source O

\\s,/

15 term was, you know, X many million curies, whatever X is, 16 but because of the fact that it was a long, a prolonged 17 release complex meteorology, I don't know that that conveys 18 enough information about the actual doses received.

19 In fact, in all of the research that I did on 20 Chernobyl I never really got a good feel for the dosimetry.

21 And one thing that I think needs to be there as a matter of 22 comparison, if nothing else, is well, we've got some 23 estimates of what thyroid doses these people were, what 24 other dosimetric estimates do we have?

Do we know what 25 their external gamma dose rates were?

Do we know what other

()

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61 1

organ doses may have been based on other radio-nuclides that l\\

2.

they were inhaling, ingesting or whatever it was.

d 3

You know, it's one thing to look at -- to draw a 4

little box around radio-iodine and the thyroid, but I think 5

you have to look at the whole p

re; otherwise, you may be d

6 led to make some conclusions that may or may not be 7

appropriate.

The technical -- the section on just what 8

happened at TMI (sic), I don't know that there's much 9

dispute about that.

If anybody's got any issues on that.

10 That's section I -- excuse me, section V there, V.

Am I 11 looking at that wrong?

12 CHAIRMAN MOHSENI:

No, that's right.

13 MR. HARDEMAN:

I don't know how that got numbered 14 V but that's all right.

()

15 CHAIRMAN MOHSENI:

Any comments on the Chernobyl 16 description in the write-up?

Any important factors we need 17 to highlight, describe that we haven't?

Yes.

18 MR. NAWOJ:

It occurs to me as he was talking that 19 maybe the reason the dosimetry wasn't all that good was l

20 because it was so complex.

The models that we use now, you 21 know, for releases are not terribly sophisticated and/or 22 accurate and, you know, you've kind of got your little 23 keyhole and that tells you where the plume is and that's 24 where you evacuate.

25 And then you look at the Chernobyl footprint and l

l l

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62 1

it's all over the plot, but when you realize -- when you

()

2 look at that plot it's taken them years to develop that.

So 3

if you wait for that kind of plot to do your protective 4

action, folks are going to be in place perhaps for years.

5 MR. HARDEMAN:

Well, I think --

l-6 MR. NAWOJ:

I might be a little bit facetious 7

there but, you know, it's not easy to figure that out while 8

the plant is going south on you.

9 MR. HARDEMAN:

Where that comes into play is not 10 necessarily at the point where you are trying to determine 11 whether or not to take protective actions or which 12 protective actions are appropriate but going back and taking 13 a look at the accident to determine what does this really 14 mean?

I mean, yes, it's fairly indisputable that there has

()

15 been an increase in thyroid cancer among the young in 16 certain populations near Chernobyl and I.think it's been 17 automatically assumed, and I may be stretching a little bit 18 there, that that was due to iodine 131 inhalation.

11 9 And my contention is that I don't think the 20 dosimetry data are hard enough that you can actually make 21 that -- make that link.

It's not strong enough to prove 22 that causation.

There are questions -- the only hard 23 dosimetry that I know of were some measurements in, I forget 24 which country it was, where they made thyroid measurements 25 some four days into the incident.

I can't remember which O-ANN RILEY & ASSOCIATES, LTD.

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country that was.

So I was asking the question before we

()

2-got started today, you know, did the Soviet reactor system, 3

did they have the same level of environmental monitoring 4

off-site that we have in the United States in terms of 5

having TLD's ringing the plant so that they could go out and 6

collect those.

7 So all of the -- all of the dose reconstruction 8

work, if you want to call it that, is based on computer 9

modeling.

A lot of it is based on simplifying the 10 assumption that wherever you find cesium, you're going to 11 find iodine and that that cesium to iodine ratio stays 12 constant over a large geographic area which is probably not 13 true.

There's a lot of questions as to how valid that 14 dosimetry data is in terms of looking at what happened and

()

15 saying, this is what caused it.

16 MR. NAWOJ:

I understand that and I think you're 17 on the right track.

My concern is, in a response mode, h

18 particularly in the U.S.

it's anticipatory.

19 MR. HARDEMAN:

Yes.

20 MR. NAWOJ:

You're looking at projections.

You're 21 looking at the prognosis of the reactor and you're making i

22 corrective actions based upon that.

Your protective action, 23 your primary one is going to be evacuation.

l 24 MR. HARDEMAN:

Uh-huh.

25 MR. NAWOJ:

If you get the KI or even if you get O

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20036 (202) 842-0034

64 1

the KI for emergency workers, it's going to be basad on

()

2 that.

The other stuff is going to come afterwards when you 3

get folks out there on the ground who can do measurements j

4 and that is going to take time and I suspect more time than l

l 5

a lot of folks anticipate.

Probably it will occur well 6

after protective actions have been implemented.

I 7

Now, your evacuation starts.

It takes so many 8

hours and then it's done and then you've got all the time

)

9 you want to develop monitoring data and whatever and 10 determining what actually came out and where.

11 CHAIRMAN MOHSENI:

Yeah, go ahead, Aubrey.

12 MR. GODWIN:

I guess a couple of points I think 13 need to be made.

First of all, the lack of a key pattern 14 around Chernobyl probably is not due to being waiting 15 several years to do the dosimetry and do the measurements as 16 much as it is the fact of the accident extended over weeks 17 really and you had this continuous release and the wind kept 18 shifting around, so the key hapt moving.

19 MR. NAWOJ:

My point is the picture there has been i

20 developed and refined over a number of years.

Don't tell me 1

21' that somebody did that with their little PC and it came out I

I 22 like that.

23 MR. HARDEMAN:

No, no, I'm not trying -- I'm just

{

24 saying that the data --

25 MR. NAWOJ:

There's no model that does that.

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MR. HARDEMAN:

And it continues to be refined,

()

2 too.

The source term was just revised less than a year ago.

3 MR. GODWIN:

The other part of it has to do with 4

there's no real good definition of the doses that was j

5 actually received in the Belarus area, even though they talk 6

about it, they have a table in I guess one of -- in this 7

document, I guess.

It talks about the dose range is less 8

than 10.

They had 14 segments, average dose was 6.1 rem.

9 3'

not sure whether we want to talk about it here or 10 whether we want to look at it or look at it when the FDA is 11 here, but there's going to be a PAG developed out of this 12 eventually somewhere.

13 That PAG will need a technical support to 14 support -- even if it stays the same, it ought to be updated

)

15 to show the technical support for the number that they're 16 using.

I think that's where it needs to be in the 17 establishment of the PAG, where the technical support is for 18 that number.

But if it's not there, then there ought to be 19 at least some passing mention of the doses received by the 20 particular children in the Belarus area a little bit more 21 definitive than this single table here.

22 MR. HARDEMAN:

Well, the other thing that I was 23 getting from my comment is -- and I went back and looked at 24 the paper that some of this was derived from, in particular 25 this table.

For one, I don't understand the term " Person O

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year-rem" and maybe somebody can explain that to me, why the 2

year figures in there but the other thing that's missing 3

here is it looks like again, we've drawn this very narrow 4

box around radio-iodine and said, "Well, here's what the 5

thyroid CDE was due to radio-iodine, whether inhaled or 6

ingested", but there's not comparison as to what the

]

7 external radiation dose was.

8 MR. GODWIN:

Or even an estimate.

9 MR. HARDEMAN:

Or even an estimate and whether 10 that was large enough in and by itself to have cause and 11 effect.

I mean, I think we agree, based on all the studies, 12 that external radiation, I don't want to say has been 13 proven, that may be a little strong, but it is felt that, 14 yes, externa' radiation to the thyroid can cause cancer.

I 15 don't know what the limitations are on that in terms of what 16 the dose probabilities are.

17 And somebody please explain to me that " Person i

18 year-rem", term in there.

I don't know how that --

i 1

19 CHAIRMAN MOHSENI:

Yeah, that's -- ignore that.

20 It's a person rem.

21 MR. HARDEMAN:

Okay, all right.

I looked at that 22 and I tried every way imaginable to come up with that and 23 couldn't figure out where that came from.

24 CHAIRMAN MOHSENI:

Yeah.

25 MR. GODWIN:

At any rate, I think that that kind ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l 67 of information ought to be supporting the FDA PAG though, 1

()

2 rather than here, but if it's not there, it needs to be in 3

here.

l 4

MR. SHERIDAN:

Could you be moi. specific?

What 5

kind of information --

6 MR. GODWIN:

I think there should be more 7

dosimetry information available in one of the two places.

8 CHAIRMAN MOHSENI:

Chernobyl dosimetry.

9 MR. GODWIN:

Chernobyl dosimetry, particularly --

10 well, apparently WHO is basing thei s mostly on the Belarus 11 experience.

So, you know, whatever the FDA elects to do 12 thair PAG's on or EPA, I think it would be well to have some 13 discussion about the dosimetry so that the reader that may 14 be technically inclined or has some basis for saying that

()

15 this is a valid dosimetry program that they had.

16 MR. HARDEMAN:

Do you know if these people have 17 whole body counts?

18 MR. GODWIN:

It's not clear from anything I've 19 read.

20 MR. HARDEMAN:

What else they had?

I mean, the 21 only thing that I saw on -- the only hard dosimetry, I 22 guess, if you'd call it that, was thyroid counts that were 23 done several days into the incident.

I can't remember right 24 off the top of my head which country that was.

I guess my 1

25 position just from a philosophical standpoint is I don't l

I l

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know that the dosimetry that we have access to supports the i

!r%'t 2

conclusion that says, " Iodine 131 inhaled / ingested led to V

3 pediatric thyroid abnormalities be they cancers or whatever 4

else".

5 MR. GODWIN:

And I think it's important for the 6

decision maker to have access to that information because 7

that will determine a part of the decision.

The decision 8

maker needs to know whether it's inhaled --

9 MR. HARDEMAN:

Or ingested and that was the other 10 part of that is that there's no pathway information.

11 CHAIRMAN MOHSENI:

Let me ask you this; Chernobyl 12 dosimetry is not the way you want it to be in terms of being 13 able to look at --

14 MR. HARDEMAN:

I understand.

t(,,/

15 CHAIRMAN MOHSENI:

Now, let me ask you this; if we 16 search -- do further search on finding dosimetry from 17 Chernobyl and if we cannot conclusively come up with the 18 right number, figures that can give us the basis for making 1

i 19 any conclusions, is it fair to say in this document that 20 conclusions cannot be drawn relating to dose released from 1

21 Chernobyl and the increased incidents of thyroid cancer?

22 MR. GODWIN:

I think we could but there's still --

l 23 CHAIRMAN MOHSENI:

We know they're connected but 24 we don't know dosimetry-wise how.

That'-

~ mportant to note.

i l

25 MR. GODWIN:

And I think that, you.'now, the ANN RILEY & ASSOCIATES, LTD.

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proper. place I believe is with FDA/ EPA's PAG's.

That's

)

2 where I think that belongs.

But if it's not going to be 3

there, it needs to be in this document, because I think that 4

is an important piece of information for the decision maker 5

to have.

6 MR. HARDEMAN:

You made a statement in Washington 7

when we were talking about the WHO document that some of the 8

doctors there felt strongly that they were seeing effects at 9

the 1 rem rate.

10 MR. GODWIN:

Right.

11 MR. HARDEMAN:

And, you know, my question is, how 12 do they know it was 1 rem.

If the -- you know, if all the 13 dosimetry is based on these mathematical models and not on 14 hard measurements of human beings, how do they really know

()

15 it was 1 rem and not 10 or 50 or 100?

16 MR. GODWIN:

That's why I think it's important for 17 the decision maker to know how valid this information is 18 going to be.

19 MR. HARDEMAN:

And that's 1 rem for the thyroid 20 compared to how many rems from external.

21' MR. SHERIDAN:

There was a study that I read 22 recently that had some charts in it.

I'd be happy to have 23 it faxed on and share it with everybody.

I may even have i

24 gotten it here, although I don't think I did.

It had some 25 charts that indicated that there were -- there was a clear O

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70 l

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increase in thyroid cancer and I don't know what the level i ()

1 2

of exposure was, but it had -- the study was done with 3

children born before Chernobyl and children born after 1

4 Chernobyl.

5 CHAIRMAN MOHSENI:

Well, yeah, if it is the one 6

that we have referenced --

7 MR. SHERIDAN:

It may be referenced in there.

1

)

4 8

MR. GODWIN:

It's in there.

There is one in here.

9 I'm not sure it's the same one.

10 MR. SHERIDAN:

I'm not aware that there's a new 11 one, so we used the -- we know there is an increase in the 12 incidents of thyroid cancer in Belarus, Ukraine and parts 13 even of Russia.

We do not have the clear connection to the 14 dosimetry the result.

One can make certain conclusions so

)

15 far.

16 We know an accident occurred and, you know, years 17 later this is what they're seeing and this is their --

18 they're saying it's due to that event.

The dosimetry is

}

19 needed because we're looking at a narrow relationship.

We 20 want to know to what extent it was due to inhalation, to 21 what extent the contribution of doses from ingestion'and to 22 what extent it's from external gamma.

23 MR. GODWIN:

Right.

24 MR. SHERIDAN:

If it's external gamma, you can't 25 do --

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MR. GODWIN:

Or internal gamma, inhaled gamma

()

2 emitters, you know, like cesium goes everywhere in the body.

3 MR. SHERIDAN:

We need to be eble to actually use 4

the Chernobyl experience for the policy making, you know, 5

EPA /FDA.

The information they need is really the 6

contribution, relative dose contribution from the different 7

pathways so that they understand the value of KI, because 8

that's the connection.

9 MR. GODWIN:

But again, that technically should be 10 part of, I think, the PAG protocol.

11 MR. SHERIDAN:

Yes, yes.

12 MR. McNUTT:

Aby, what are the chances of getting 13 that information?

I mean, aren't we looking at the smoking 14 gun as opposed to the circumstantial evidence here?

(

15 CHAIRMAN MOHSENI:

I think to answer your 16 question, it's not that we haven't looked.

We have looked.

17 We haven't found and it says in our report, in our original 18 report, that data Ehowing thyroid dose in Belarus has a 19 function of distance which it important because cancer, 20 incidents of cancer was given to us as a function of 21 distance, from Chernobyl could not be found in the 22 literature.

That's an essential connection that we're 23 lacking.

And that's why we can't -- you know, Poland, for 24 example, the connection between Poland having used potassium 25 iodide and the fact that they did not find any increased i

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incidents of thyroid cancer amongst children born in a

()

2 certain age group-is also connected to whether or not we 3

know what the doses were that they were exposed to.

4

-MR.

HARDEMAN:

Or would have been exposed to 5

without taking KI.

6 CHAIRMAN MOHSENI:

External, internal, you know, 7

and we're talking about large distances.

Poland is -- you 8

know, the uncertainties that Mike was talking about, it's no 9

longer -- we can't use projections.

We have to kind of have 10 an evaluation system of dose assessment.

We've got to do --

11 assess the dose to the whole body, to the different organs.

12-Now, that's pertinent to this because indeed the 13 Chernobyl experience we have cited as a new event that 14 should -- could potentially impact our thinking process,

()

15 vis-a-vis, the usefulness of KI.

However, the missing link 16 is there.

We need to somehow be able to address that.

If 17 we can't find information enough to connect, then what 18 conclusion can we draw from Chernobyl?

19 MR. McNUTT:

It's there as well for the other 20 protective action, the primary one, which is evacuation.

21 They didn't implement that for a number of days.

Had they 22 done that promptly, we might still have the missing link 23 with respect to iodine but the picture would be a lot 24 different because there may be no increase in thyroid 25 cancers because the protection action, evacuation, would

['

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73 1

have eliminated it.

/' \\

2 MR. HARDEMAN:

So you're saying maybe

\\us/

t

)

3 hypothetically -- go ahead.

1 4

MR. GODWIN:

That may not track because a lot of 5

their doses were through the milk chain.

See, that's the 6

difference, a lot of the dose is through the milk chain.

7 MR. McNUTT:

That was mentioned with the iodine, 8-certainly.

But we're looking only from the inhalation 9

pathway with respect to this document, not from ingestion.

10 MR. GODWIN:

We are but they weren't.

11 MR. HARDEMAN:

So what you're saying is maybe go 12 through some kind of hypothetical calculation that says, 13 okay, assuming this accident -- assuming that this accident 14 could occur in the U.S., which we all_ recognize is a big l( )

15 stretch --

16 MR. McNUTT:

With all that kind of iodine getting 17 out there.

18 MR. HARDEMAN:

-- right, and now overlay the 19 existing emergency preparedness programs over the top of l

20 that and you say, when this thing happens or if -- assuming 21 in the U.S.

that you're going to see precursors to it, you 22 evacuate people.

Now, what are you left with?

Now, what 23 kind of doses are you left with.

24 MR. McNUTT:

You've got your "Aw shucks" scenario.

25 There's no decision making as to what should we do.

It's ANN RILEY & ASSOCIATES, LTD.

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everybody out, so do it and we get everybody out. within a I

2 reasonable amount of time.

We don't hem and haw for two or

(

3 three days and say -- whatever the number was, and what j

4 consequence would you look at then as opposed to the l

l 5

consequence that you're looking at.

6 MR. HARDEMAN:

That's kind of one of the things that if you skip down into Section 6 where I was talking 7

8 about implications of Chernobyl on emergency preparedness in 9

the U.S., it -- the notification system kind of gets to 10 that.

One of the things that we talked about at the last 11 meeting was that IAEA emergency plans, which if you look at 12 those emergency plans, the event that most often triggers 13 you into getting into that plan is I have taken a radiation 14 measurement in the environment and it is abnormally high.

()

15 Therefore, something funny is going on, I'm going to declare 16 a radiological emergency.

17 MR. McNUTT:

Well, another element, the wind was 18 coming from them, so it must be them.

19 MR. GODWIN:

Well, you all need to understand a 20 couple of things about the eastern European monitoring 21 having worked with the Lithuanians and the Kosakis, there is 22 no communication between the off-site people, particularly 23 when'they're in another country and the reactor.

And the 24 standing procedure is that every so many hours the police 25 department takes a radiation reading because that's the way

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they're going to find out about the accidents.

2 MR. HARDEMAN:

And that's the way IAEA's plan 3

reads.

4 MR. GODWIN:

Right, and let's go back to another 5

thing about the accident.

Looking at the survey, for 6

example, accidents, the iodine release according these 7

carefully chosen documents no page 25 of the defunct book, 8

shows that the earliest one we can expect release time on is 9

eleven and a half hours.

Now, if one gets the pre-cursor of 10 by-passing -- let's see, by-passing the high pressure steam 11 brakes is what they're talking about in that case, with no 12 sprays operating, and there's a -- the vessel is melted in 13 effect, if I remember all this correctly, do you think that 14 there might be enough pre-cursors to evacuate it 10 miles?

15 MR. HARDEMAN:

Yeah.

16 MR. GODWIN:

Can you get your people out within 11 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />, the next question.

Are there sites in the country 18 where they can't get them evacuated?

19 CHAIRMAN MOHSENI:

Probably.

20 MR. GODWIN:

In that case, then those people are 21 possible candidates to receive in excess of 1 to 25 rem.

If 22 you believe that there are -- reactive series 4 is a 23 possible accident.

It releases a very small amount of 1

24 iodine, though, compared to the others but it does release j

25 it.

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MR. JAMGOCHIAN:

The source term you're looking at

()

2 is only for one reactor source.

3 MR. GODWIN:

I understand that 4

MR. JAMGOCHIAN:

As you recall, the scenario that 5

6 MR. GODWIN:

That's PWR, if I'm correct, isn't it?

i 7

MR. HARDEMAN:

Surrey, yes, PW.

8 MR. JAMGOCHIAN:

But if you recall, when we f

9 established the 15 minute notification, okay, that was at 10 that time, 1150 had not been written.

Wash 1400 was the 11 best document we had available, but there was a release 12 within a half hour, within 30 minutes.

13 MR. GODWIN:

On Wash 1400.

14 MR. JAMGOCHIAN:

On Wash 1400.

Now, I understand g_)

15 1150, I think the worst case scenario was a release within 16 an hour, maybe and hour and 15 minutes, not very much longer 17 because we considered modifying that notification of a half i

18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

So each plan has a different fingerprint, if you 19 would.

So to follow that thought process may not be totally 20 correct because I'm listening to you and I'm saying, "Well, 21 why have that half hour notification".

22 MR. GODWIN:

Well, there are other accidents --

23 but there are other accidents that may not release iodine in 24 that short of time.

So this was the iodine released 25 scenarios only, appreciable iodine releases.

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MR. HARDEMAN:

That's why I was saying earlier --

()

2 MR. GODWIN:

So if you're looking at the other 3

scenarios, yeah, you do have a shorter time but I was 4

looking at the iodine release scenarios which these were 5

chosen as examples.

I assume that they had some relation, 6

too.

7 MR. JAMGOCHIAN:

You know, one thing I wanted to 8

mention, Bill McNutt mentioned, aren't we looking for a 9

smoking gun.

I just want to share with you, my job at NRC 10 is to write regulations.

In so doing, I come in contact or 11 work with a great number of members of the public.

For some 12 reason my phone number is in the public domain and I get a 13 lot of phone calls from folks --

14 MR. HARDEMAN:

It's on the Web, too, so don't 15 worry about it.

16 MR. JAMGOCHIAN:

-- wanting to discuss this and I 17 tried to characterize the Chernobyl data that's in that new 18 reg 1633.

And so many people, I bore them to death trying 19 to tell them about the dosimetry and the iodine starved 20 populations and the bottom line, the public tends to nail me 21 against the wall every time and they say, " Wait a minute, in 22 Poland they took KI.

There are no kids with Thyroid cancer.

23 In Bel rus uney didn't take KI and there's a projected 3500 24 kids with thyroid cancer", end of discussion.

25 They don't want to know about the dosimetry.

They

[

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78 don't want to see the smoking gun and I think a lot of you 1

()

2 states, you're going to come up to very fundamental thought 3

processes.

They don't want to know all the technical stuff.

4 MR. HARDEMAN:

We're going to come up against 5

that, Mike, but Aby -- I think Aby put it right; do we 6

really have enough data to know what would have happened in 7

Poland had they not administered KI?

It's kind of like me spraying a can of elephant repellant around here and saying, 8

9 "Well, I don't see any elephants, so it must have been 10 effective".

i 11 MR. JAMGOCHIAN:

3e way Aby characterized the 12 charter is very accurate, okay, but I also wanted to chare 13 with you some of the experience I've had where the members 14 of the public have nailed me.

Okay, "We don't want to know

()

15 all that technical stuff.

You're a nuclear engineer and 16 yes, you understand it",

at least they think I understand 17 it, okay, but the bottom line, that's what states are going 18 to be up against.

l 19 MR. HARDEMAN:

Agreed.

20 CHAIRMAN MOHSENI:

Okay, let's go on.

Yes.

21 MR. LANTZ:

Mike Lantz, Arizona Public Service.

22 You actually affected my question by, you know, talking 23 about the Poland experience and their KI but you guys, in 24 your discussions you led me to think that the Belarus 25 experience is maybe not the best data in the world to make

(

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all these decisions on since they are large doses with, as

[ )

2 described, a large uncertainty.

And what -- and these are l

\\/

i 3

doses well over 100 rem at the top.

4 What might be a better data set to look at is 5.

lower dose regions like Poland but -- that's why I'm affect 6

here, might be better to look at is lower dose regions where 7

the max dose rates or max doses are more like 10 rem.

And 8

maybe the dosimetry is slightly better because it might be 9

further down in distance and time where they were finally 10 getting better measurements.

But that's what I would 11 suggest is to evaluate not -- and there's some comments 12 about Poland that says because of the low iodine 13 concentrations, it's doubtful that epidemiological studies 14 would detect excess cancers.

)

15 I guess I would just suggest not down-playing 16 Poland so much and any other regions having lower doses, 17 because if you come to the conclusion -- if WHO comes to the 18 conclusion that doses as low as one RAD can cause thyroid 19 cancers, then those areas where the max doses were 10, 20 certainly need to describe that same situation, need to see 21 thyroid cancers.

So I guess I'm suggesting now down-playing 22 those low does regions, that's all.

23 MR '. HARDEMAN:

That was the one problem that I had 24 with the Belarus data and I think the only reason that we i

25 went with the Belarus data was despite all the problems that ANN RILEY & ASSOCIATES, LTD.

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there are with it, it's still the best data set that's out

()

2 there.

I was a little disappointed that it didn't go down 3

-- you know, that there wasn't another column on top, a less 4

than 1 rem.

5 MR. GODWIN:

Again, I think that's basically a PAG 6

problem at this point and we need to wait for the PAG folks 7

to work it over.

8 CHAIRMAN MOHSENI:

PAG, yes, indeed, but there's 9

also a question of whether or not it serves any purpose to 10 begin with and then if it does serve a purpose, should there 11 be a PAG for it.

12 MR. HARDEMAN:

Well, at what level.

13 CHAIRMAN MOHSENI:

Yeah, at what level.

So 14 Chernobyl was suggested to be a watershed.

15 MR. HARDEMAN:

Proof positive.

16 CHAIRMAN MOHSENI:

Yeah, that you absolutely need 17 KI because here's proof black and white.

We are looking at 18 the data, if there is any and not quickly coming to that 19 conclusion that indeed we're -- you know, the facts are 20 there.

You look at the facts, but you don't see the 21 connection that -- Poland for example, Polish experience, 22 versus the Belarus experience, the difference was one 23 distributed KI and the other one didn't.

Therefore, you 24 know, don't tell me any more, don't confuse me with 25 additional facts.

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r 81 l

1 One had KI and the other one didn't, and one has

()

2 cancer, the other-one -- wcll, obviously, when you look at 3

it more closely, that's not the case and it's very important 4

to recognize that the -- when we look at the Hanford health 5

study in the next few days, you will see that it's not 6

straightforward.

We -- it's one thing to try to prepare a 7

document for trying to tell the public in five seconds what 8

the answer is to your big problem.

It's another thing to 9

put enough information in front of decision makers to make 10 them aware of what the pros and cons are and that's what i

11 we're trying to develop here, pros and cons for decision 12 makers, not the members of the public necessarily, decision 13 makers in the states and local communities who have a strong 14 background in radiation science and understand the issues of

()

15 emergency planning and it's for them to make the decision as 16 to whether or not they want to have a KI program for -- and 17 they are the ones who are going to look at Chernobyl and 18 say, "Did it benefit?

Who -- the parts of the Soviet Union 19 that did not have KI, did they suffer as a result?

20 had those that had it, did they benefit as a i

21 result"?

We're trying to answer that question and I don't 22 think it's straightforward from the data because there's a i

i 23 lot of mis-information out there that we just canno" see the 24 facts.

We're trying to find out what the exact anicars to 25 those questions are so that the decision makers have it in e

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front of them.

That's the goal.

Dick.

l()

2 MR. COWLEY:

I guess my question is, what do we 3

really expect to get from the Chernobyl data?

Is there any 4

area that actually has plume air sample data with the 5

isotopic mix, so that we can definitively say there was this 6

much iodine exposure and it's not a result of ingestion of 7

iodine for months and years later.

I mean, there's so much 8

contribution from ingestion, especially in the Ukraine and a

9 Belarus that --

10 MR. HARDEMAN:

And that's part of the point.

If 11 you read down in Section 6 where we're talking implications, 12 that there is insufficient data there to actually nail down 13 what the contribution to ingestion was versus what the 14 contribution due to inhalation does, but then everybody

()

15 who's looked at the data feels confident that the bulk, 16 however you define the bulk of those doses were due to 17 ingestion pathway, which we're automatically saying are out 18 of consideration as far as we're concerned.

19 MR. GODWIN:

No, no, we're not saying that.

We're 20 just saying that we're not going to pursue the ingestion 21 pathway for our protective actions in this country because 22 we don't need to.

23 MR. HARDEMAN:

Correct.

24 MR. GODWIN:

But as far as how the item got to the l

25 thyroid, we have never said that the items from ingested

()'

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dosage is different from the inhalation dose.

Be careful.

2 MR. HARDEMAN:

Point well, taken, dose is dose is 3

dose.

4 MR. GODWIN:

Right, except if it's external it may 5

be different.

1 6

MR. HARDEMAN:

Right.

7 MR. GODWIN:

But I still think that the decision

)

8 maker needs to have some idea of the degree of confidence in 9

the dosimetry that went into setting the PAG.

10 CHAIRMAN MOHSENI:

I agree.

11 MR. GODWIN:

And I think that most logically is 12 the PAG place but I would like to have it reserved that if 13 the FDA does not address it, that we come back and put 14 something in here about it but I still think that FDA and 15 EPA ought to be the place where it's placed.

16 MR. HARDEMAN:

To get back to the question of 17 whether we're asking for something that exists or not, I 18 would almost surmise that in terms of contemporary air 19 sampling data, things of that nature, you're not going to 20 find that.

You may find some of the -- you know, Finland, 21 Sweden, places.',ike that, they may have some air samples 22 after their flow monitor started going off but close into 23 the plant, probably nothing.

l 24 Whether you've got any contemporary direct 25 radiation measurements or not, I wouldn't know.

I would O

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84 l

1 kind of be surprised tripped across some of that stuff,

()

2 which again calls all of the dosimetry really into question 3

and how can we make this conclusion is a leap of faith, if 4

you will, that says you know, just because we had this much 5

of a release of iodine, that it necessarily caused this.

6 MR. GODWIN:

Well, I think that's a PAG decision 7

about that determination, not for us.

8-MR. HARDEMAN:

Yeah.

9 MR. GODWIN:

And all we need to do is once we get 10 the PAG is to make sure that the backup to it is included 11 somewhere and I really hope that FDA and EPA do it, to be 12 honest with you.

13 MR. HARDEMAN:

I hope they do the research anyway, 14 because I don't want to have to do it.

(b

_,/

15 MR. GODWIN:

I'm chicken to.

16 MR. SHERIDAN:

Because they can.

17 CRAIRMAN MOHSENI:

Well, you know, we'll -- by the 18 end of this week, I'm really curious to see what you all 19 think about the Hanford study because, you know, thinking 20 PAG's, things are not getting any easier for us looking at 21 Hanford.

It's becoming -- and FDA is aware of that.

And 22 FDA will be here and they will discuss but I know that they 23 are struggling with the information in front of them.

l 24 It's not an easy straightforward thing #ar them to 25 do.

Dick, did you have something else?

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MR. COWLEY:

I guess the only comment was still

()

2 that even if we have areas where we have a definitive air 3

sample and we could get a positive isotopic mix, do we know how much the ingestion of iodine in that same area may have 4

5 been causative more than inhalation?

Is there any way at 6

all to --

7 CHAIRMAN MOHSENI:

In this document that we 8

withdrew, we have the cesium contamination '.evel on the 9

ground after many years and in it we say that we don't even 10 know the iodine relative abundance.

11 MR. COWLEY:

Right, because there's no guarantee 12 it stays proportional at all.

13 MR. HARDEMAN:

But it was assumed tu be a constant 14 ratio with the same pattern which --

15 CHAIRMAN MOHSENI:

No, we said, even if you assume 16 then you can draw these conclusions but we know they were 17 not.

18 MR. COWLEY:

Which would be making a worst case 19 assumption.

20 CHAIRMAN MOHSENI:

Indeed, it was not a constant 21 continuous ratio but for the -- you know, even simplifying 22 the problem so that we can draw some conclusions, you know, 23 we made the assumption that the ratio remained constant on 24 the ground and no clearly we have gaps here we need to fill 23 and that's what this KI Core Group ought to kind of focus

.i h

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on.

If we can fill the information because some publication

()

2 has provided some new information on the dosimetry, that's 3

great, but if we don't get the, we're going to put in there 4

saying that the dosimetry wasn't there for us to draw the 5

conclusion as to what the effectiveness of KI might have 6

been in Belarus or elsewhere.

7 But certainly we know things that did not happen.

8 Protective actions such as evacuation did not occur but at 9

the same time what makes matters a little bit more complex 10 is that thyroid cancer was found way out there, not so much 11 close in.

Whether it's related to population density, I 12 don't know but a complicating factor is that thyroid cancer 13 is further away -- in this country it would be way out, 14 outside your 10-mile EPZ.

()

15 What does that mean to us?

Is it because they 16 continued ingesting contaminated food in the 10 to 15-mile 17 equivalent in this country?

Then if that's the case, was it 18 iodine 131 that made the major contribution to the dose or 19 short-lived radio-iodine?

Is it the short -- because if 20 it's iodine 131, then, you know, we're going to hear about 21 it on Thursday, that that may not be'the biggest culprit.

22 But if it's short-lived radio-iodine days after, 23 you know, 10 half-lives which is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, you should 24 almost, you know, gradually see that disappear from the 25 scene.

We need to kind of get our hands around this

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87 1

understanding what the dose was.

We know we have cancer but j()

2 we don't quite know what to do with the connection yet.

l 3

Okay.

1 4

MR. HARDEMAN:

Okay, well, is it I mean, I just 5

made the statement in there that the dosimetry are 6

inconclusive and I don't think there's anybody around the 7

table that would disagree with that.

I hope not.

8 ChalRMAN MOHSENI:

If you find any dosimetry that 9

you think is the answer, anybody on the Web, anybody with, 10 you know, connection to World Health Organizations such as 11 ABRI (ph) or IAEA, we've researched and we haven't come up 12 with the kind of data base that we need to draw conclusions

(

i 13 ourselves.

14 MR. HARDEMAN:

I've even looked at scores of

()

15 Russian websites and still haven't come up with anything.

16 CHhIRMAN MOHSENI:

And that's an important 17 conclusion.

If we cannot connect it, then it has to be said 18 because right now the impression outside is that it's a 19 perfect example of how you could distribute KI and protect 20 thyroid cancer and I think we need to address that.

If 21 that's the case, then it needs to be said and if that cannot 22 be concluded, it should be said.

23 MR. GODWIN:

Well, I hope that the FDA and EPA 24 will say it in the documents and take the appropriate PAG 25 adjustments or not adjustments.

l I

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MR. HARDEMAN:

Well, the three big areas that I

(

2 looked at in looking at the implications was, one, the 3

differences in the RBMK 1000 design and the current 4

generation U.S. white water reactor designs and what that 5

means in terms of accident probabilitier, and I'm not going 6

to get into all the nucleonics and negative void 7

coefficients and things like that; suffice it to say that the graphite moderated reactors are more prone to this type 8

9 of accident than the white stater reactt 10 Then hit on the notification system which I eluded 11 to earlier, about the notification system for Chernobyl for 12 most of the folks in the off-site was we detected something 13 in the atmosphere.

I mean, how did we all find out about 14 Chernobyl.

Was it the Fins who had their flow monitors 15 going off.

16 MR. GODWIN:

Sweden, I think.

17 MR. HARDEMAN:

The Swedes when plant employees 18 were going into work.

So that's not the kind of 19 notification system that we like in the United States.

It's 20 not the kind of system that NRC has mandated and FEMA has 21 mandated if you want to put it in those terms.

We like to 22 think that we can do a little bit better than that.

23 We talked about the ingestion pathway for the 24 purposes of protective actions, we weren't going to use KI 25 as an alternative for interdiction of food stuff.

That we i

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1 felt comfortable that the magnitude of accidents that could

. ()

2 occur that the food, the milk shed in particular, but the 3

overall food network, if you want to refer to it as that in 4

the United States, could withstand that sort of insult 5

without resulting in any major disruptions in the food.

You 6

may have minor availability problems locally.

7 And the conclusion there, and you all can throw B

rocks at it if you want to, but combination of conditions 9

that resulted in large thyroid doses from the Chernobyl 10

accident, i.e., lack of containment, lack of notification, 11 lack of interdiction of contaminated food stuffs, et cetera, 12 does not exist for domestic commercial power reactors.

One 13 should be extremely cautious in justifying the use of 14 potassium iodide in the U.S. based on the experience in

()

15 Belarus, Russia and the Ukraine during and after the 16 Chernobyl accident.

17 MR. GODWIN:

I would suggest that instead of 18 saying be cautious that you carefully consider.

It sounds 19 like you're drawing a conclusion more than I thought was 20 going to be drawn in here.

21 MR. HARDEMAN:

A point well taken.

That might 22 have been a minor editorialization on my part.

I was trying 23 to keep it open and above board.

I would accede to that.

24 You look like you had a point when I was talking about the 25 ingestion pathway stuff, too, Aubrey.

I think.

You were n

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kind of -- I saw that eyebrow raise up and it looked like

()

2 you were getting ready to jump in there.

3' MR. GODWIN:

No, I think I already covered it 4

earlier.

5 MR. HARDEMAN:

So I don't know how much more we i

6 can say on Chernobyl other than it just --

7 MR. GODWIN:

We did get a concurrence on the 8

Agricultural Department, this statement is correct about 9

bits being available; is that correct?

10 CHAIRMAN MOHSENI:

I thought we got that from 11 FEMA.

12 MR. GODWIN:

FEMA, okay.

13 MR. HARDEMAN:

I don't think we ever took it to 14 FDA or USDA.

15 MR. GODWIN:

The other point about the milk, is 16 you don't have to worry about milk for the entire 17 population, just certain critical parts of it and that helps 18 a whole lot, so you may not have the milk available for 19 everybody but you will enough for the critical population.

20 MR. HARDEMAN:

And, of course, the, I guess, 21 sister version of the World Health Organization dealing with 22 childhood and parenting issues recommends that you don't 23 give children under the age of 12 to 18 months cow's milk 24 anyway.

25 CHAIRMAN MOHSENI:

Any comments.

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MR. HARDEMAN:

Just as a point of reference.

2 CHAIRMAN MOHSENI:

Any comments on the 3

implications of the Chernobyl accident on the U.S. emergency 4

preparedness?

This is now important.

Please make sure you 5

all speim up, help us characterize it appropriately.

6 MR. McNUTT:

I think what Jim has put in there is 7

pretty obvious but I'd just, you know, repeat what I said 8

before.

You don't find the smoking gun the direct link but 9

that doesn't mean it isn't there and so I think -- you know, 10 I think we're painting ourself into a corner.

A reasonable 11 person could say, "That's enough evidence for me".

12 CHAIRMAN MOHSENI:

Okay, how do you propose --

13 propose to us, you know, not imniediately, whenever you want 14 language that helps clarify that while the data is not

()

15 there, you know, whatever you just said, do us a favor and 16 make sure that we have the language that characterizes j

17 accurately the position of this group.

18 It has implications for decision makers, no 19 question about it.

It has implications for the PAG 20 development because if FDA or EPA have data that they're 21 using from Chernobyl that we are unaware of, then, you know, 22 this is most embarrassing to the two groups not talking to 23 each other and you are both -- we have on this group both 24 EPA and FDA and we sure hope that if they're looking at 25 certain dosimetry to develop their PAG's or revise their ANN RILEY & ASSOCIATES, LTD.

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92 1

PAG's that we are made aware of so that we do not say (A) 2 something that they are not in agreement with.

3 Is that fair?

Do you have, to your knowledge, any 4

information on dosimetry that could help us gap?

5 MS. CARPENTIER:

Not to my knowledge.

I know who 6

I would ask and I'll do that and let you know, but I do not 7

believe so.

The revision of the famous EPA 400 is just 8

opening and to my knowledge hasn't had a lot of time put 9

into it, so I would tend to doubt it at this point.

10 CHAIRMAN MOHSENI:

Okay.

11 MR. SHERIDAN:

Aby, I don't know if this is 12 important now but --

13 CHAIRMAN MOHSENI:

If you think it's important, 14 then it is.

)

15 MR. SHERIDAN:

-- I wouldn't have qualified myself 16 except I don't think it is important, I guess, but forgive 17 me.

We're trying to come up with a new plan because of the 18 problems around Milestone and the lack of public confidence l

19 that has resulted there.

And I understand there are not 3

20 monitors that are electronically capable of transmitting 21 data in real time to any location.

So what we're hoping to 22 do is to build a curriculum in the school system around air 23 sampling and monitoring, so that any student, public library 24 user, et cetera, from almost any part of the country because 25 it will be on the Web, too, can monitor air samplings

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around.

()

2 We'll ring the plants with these monitors.

I'm 3

not sure but I'm excited about it, that's the only reason I 4

bring it up.

And I guess that it doesn't have any real 5

meaning here.

6 MR. HARDEMAN:

That's one of the areas that a lot I

7 of your European countries are getting into quite heavily 8

now.

We just purchased a series of automated radiation 9

monitors.

All they're looking at is gamma radiation.

10 They're not getting into doing air samples and things like 11 that.

It's just -- basically just a Geiger counter sitting 12 in a box with a modem to call back to us and the company 13 that actually manufactures those is based in Finland.

14 And Finland, rightly or wrongly, has got a

()

15 nationwide system.

I guess it's over 200 of these things 16 and you know, quite frankly it's a self-defense mechanism.

17 That's their first line of defense, they view it and seeing 18 where they're located --

19 MR. GODWIN:

Nobody calls and tells them.

20 MR. HARDEMAN:

-- because nobody calls them and 21 tells them, but we've got to be up front and recognize in 22 the document that's not the way we do business in the United 23 States.

Now, you know, there may be some trans-border 24 issues regarding Canadian reactors, but I seem to recall 25 that those states that are potentially effected by Canadian Os ANN RILEY & ASSOCIATES, LTD.

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reactors seem to have pretty good relationship with them.

2-There may be some translation problems in terms of 3

going from mega, mega beclorals (ph) to curies and things 4

like that but at least they get notified.

5 CHAIRMAN MOHSENI:

Let me read some of the 6

comments that might be pertinent from Ohio to the discussion 7

here.

"If the risk for a severe core accident of excess 8

thyroid cancer occurs well outside of a 10-mile EPZ to 9

several hundred miles, does this not mean that FEMA is 10 inappropriately using a 10-mile radius of the nuclear plant 11 for accident plume phase emergency planning?

Does this 12 change everything or should we be only considering KI

)

13 distribution for current design basis accidents not severe 14 core accidents that are highly incredible?

OQ 15 We don't see how the KI Core Group can have it 16 both ways particularly for high density northeast and 17 Midwest EPZ's.

In reviewing the Commission's words and that 18 of commissionero as they have charged the KI Core Group in I

19 addresses to them, it appears that they are not so 20 comfortable in using the 10-mile EPZ.

Hence, the 21 Commission's interest in additional suppliec of KI being

)

22 made available from federal stockpiles should they be 23 needed".

24 MR. SHERIDAN:

That's a big jump, isn't it?

q 25 MR. HARDEMAN:

Well, it sounds like they're mixing ANN RILEY & ASSOCIATES, LTD.

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apples and oranges.

I mean, if you're talking a bulk of a

()

2 thyroid dose being outside the 10-mile EPZ, I would say from 3

a population dose perspective, that's true.

But you also 4

have to look at how it was delivered, whether it was 5

ingestion or whether it was inhalation.

6 MR. GODWIN:

Individual dose basis is not true.

7 MR. HARDEMAN:

On-an individual dose basis, I 8

would bet that you're right there, but from a population 9

dose perspective, it is.

a 10 MR. McNUTT:

Whose number is the 10?

11 MR. GODWIN:

It's NRC's.

12 A VOICE:

I always thought that was NRC's number 13 that they gave to FEMA.

They're laying it on FEMA and 14 that's not -- you know, far be it from me to stand up for

()

15 FEMA.

They're off base with respect to that comment there.

16 MR. McNUTT:

Well, FEMA can take the hit.

1654 is 17 a FEMA /NRC document.

j 18 MR. GODWIN:

Well, 0396 is the one that defined 19 the 10-mile.

20 MR. JAMGOCHIAN:

0139 is an NRC/ EPA document.

21 MR. GODWIN:

I'm one of the advising people to it, 22 unfortunately.

Sometimes you have to do what you have to 23 do.

24 A VOICE:

What about beyond the 10-mile?

25 MR. GODWIN:

The consideration at the time they C/

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set up the 10-mile was that it was reasonably prudent 2

because the curies come out and drop off at approximately 10 3

miles as far as projected deaths.

You can go out further if 4

you want to -- you know, whatever you want to consider and 5

these were all -- involved accidents that are well beyond 6

design base.

This was a complete blow the head off the 7

reactor, send it through the roof and that kind of accident.

8 It was also recognized that if you established a 9

10-mile EPZ in virtually every jurisdiction, you would bring 10 on board enough decision makers to cover the spectrum of 11 problems you could anticipate if you had to expand.

So you 12 got the advantage of having the decision makers on hand to 13 make the decisions that has to go beyond it and because wind 14 speeds are typically within the two to four mile an hour

(/

15 wind speed, you have time enough to get them there and see 16 if there's a problem that you need to go beyond it.

17 It was also recognized that if you established a 18 10-mile EPZ in virtually every jurisdiction you would bring 19 on board enough decision makers to cover the spectrum of 20 problems you could anticipate if you had to expand.

So you 21 got the advantage of having the decision makers on hand to 22 make the decisions if it has to go beyond it and because 23 that wind speeds are typically in the two to four mile an 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> wind speed, you have time enough to get them there and 25 see if it's a problem that you need to go beyond it.

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That was the kind of considerations that went into

()

2 setting the 10 miles and the 50 miles.

Some consideration 3

went into the 50 miles for ingestion but it was always 4

recognized that there were scenarios that could be 5

contemplated that would go beyond the 10 and the 50 miles.

6 But it was decided that the decision makers would be 7

available.

It's very similar to the fact that you do not 8

plan to have a 747 go into Yankee Stadium in the World 9

Series.

You're prepared for accidents like that but 7'r

?

10 complete wipe-out of the stadium.

11 There are some things that are so remote that it 12 is not a good way to spend public money planning for.

And 13 that same argument was used by many states and I think Mike 14 is right in that many states looked at them and decided it

()

15 was not appropriate to spend public monies planning for the 16 rather remote issue of the need for KI.

I mean, that wasn't 17 the only reason but that was one of the reasons.

18 CHAIRMAN MOHSENI:

Let me go on with one more 19 paragraph that sheds more light.

"It is incumbent upon the 20 NRC to technically define and justify the design basis 21 accident for which KI should be considered as a supplement 22 to evacuation including defining the projected thyroid CDE 23 versus distances from the reference plant.

Probablistic 24 risk assessment could be considered in the decision.

The 25 NRC cannot merely adopt both the idealized 10-mile EPZ plume C\\

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exposure pathway boundary and the severe core accident

()

2 scenario.

They are mutually exclusive.

3 We don't see how EPA or FEMA could issue guidance 4

to states without that definition nor how states could 5

consider adoption of KI as a supplement without a technical 6

definition".

7 MR. GODWIN:

I would suggest in response to that 8

he needs to go back and read 0396 to see where that came 9

from and then he might'have to rephrase his question.

10 CHAIRMAN MOHSENI:

Any other comments?

We want to 11 close issues if we can.

Is there something here that we 12 have not discussed before?

Bill, did you want to say 13 something?

14 MR. McNUTT:

No.

()

15 MR. GODWIN:

I think that, you know, that the 16 basis that we came up with in 0396, this is merely an 17 extension of that.

You need to go back and look at the 18 basis there.

19 MR. JAMGOCHIAN:

0396, a fundamental in EP 20 regulation is that you look at a spectrum of accidents.

21 That's the magic words, quote, unquote, " spectrum of 22 accidents". You look at design basis accidents up to and 23 including the worst case scenario.

So that's really the 24 response and that's in 0396.

25 Cr. AIRMAN MOHSENI:

And that was how NRC and EPA ANN RILEY & ASSOCIATES, LTD.

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came to recognize that a 10-mile EPZ seems appropriate.

()

2 MR. JAMGOCHIAN:

It was a balancing.

3 CHAIRMAN MOHSENI:

Yes.

4 A VOICE:

It's approximately 10 miles.

5 MR. GODWIN:

A prudent decision, something like 6

that.

7 CHAIRMAN MOHSENI:

Yes, correct.

8 MR. GODWIN:

There's a couple things in 0396 that, 9

you know, this goes a little bit beyond it, because it talks 10 about getting -- not doing special decontamination surveys 11 and things wh ch are currently included in some of the FEMA 12 advice and not making special radiological arrangements was 13 also one of the items included there.

So you have to look 14 at that a little carefully when you read it and see how it O

(,/

15 matches current philosophies which have gone a little bit 16 beyond what the original import was.

17 MR. McNUTT:

Well, 0654, that's the implementing 18 planning guidance.

It's not 396, that's the planning basis.

19 MR. GODWIN:

Well, I mean, the planning basis 20 doesn't always jive exactly with the implementing documents 21 is what I'm saying.

22 MR. HARDEMAN:

That was pointed out in Orlando a 23 couple weeks ago, too.

24 CHAIRMAN MOHSENI:

Is that issue reasonably 25 addressed, then, in your opinion?

There's nothing in there

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that you want to open up?

[)

2 We have other comments that deal with our first V

3 meeting that it's on the agenda for really tomorrow since t

)

4 Jim was going to give us an extra two hours.

5 MR. HARDEMAN:

I gave you an extra two hours, use 6

it fruitfully.

7 CHAIRMAN MOHSENI:

With -- does the document 8

therefore, adequately address potential source terms that 9

we're dealing with, historical accidents?

Is there anything 10 else we need to add or change based on what we went through 11 today?

12 We've got the TMI, we've got an action item on i

13 that.

We've got Windscale.

We've got to check and see if there's more details on health consequences for that which 14 15 broadly speaking, none that we are aware of.

That's in the 16 document as we speak.

And that was on iodine release, major 17 iodine release.

There are significant pieces in our 18 original new reg that deal with other events that cause 19 thyroid doses.

So in that regard, you know, the Hanford 20 falls into that category.

21 For example, the Rochester, New York, there's a 22 discussion of the Marshall Islanders.

We have -- you know, 23 nobody has provided -- those pieces are going to stay in the 24 document if I don't hear any reasons because the public 25 comments really didn't have anything to say about those

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i things.

They basically questioned other aspects of it but

()

2 these aspects continue to remain there.

3 There are some parts that I really need FDA to 4

okay before it continues to stay there.

We have --

5 MR. GODWIN:

I think some of us want to bring up 6

the questions on the Hanford study but we need to bring it 7

up to Jim when he presents his comments.

8 CHAIRMAN MOHSENI:

Yes, yes.

9 MR. SHERIDAN:

I'm unclear and I'm sorry, I'm 10 thinking back to five minutes ago, on the 10-mile EPZ and 11 what, if anything, needs to be addressed outside of that.

12 CHAIRMAN MOHSENI:

We have to have, I think, a 13 description -- probably we can use Mike Jamgochian in 14 writing up the 0396 basis, you know, a synopsis if you will, O

g_j 15 of why mile EPZ is what we're focusing on and you know, 16 what

-rey just described and Bill.

17 MR. GODWIN:

But I think the basic question is, is 18 what is his responsibility beyond the 10 miles.

Is that 19' what you were looking at?

20 MR. SHERIDAN:

Well, no -- maybe it is actually.

21 I just think it's a void in the data right now.

I mean, why 22 would we -- clearly if we look at the Russian studies that 23 were done at Belarus, there certainly was an impact beyond 24 10 miles from Chernobyl and are we just deciding that that 1

25 was there and this is here and --

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MR. GODWIN:

Well, part of that has to do with a

()

2 lot of that was ingested pathway problems.

3 MR. SHERIDAN:

No, I understand that, I understand 4

that.

5 MR. GODWIN:

A part of it has to do with the fact 6

that they did not have secondary containment and they 7

released a whole lot more than we release here, so there's a 8

couple things as to why our curies would break sooner.

9 MR. SHERIDAN:

Right, and I guess what I'm asking 10 is that we need a statement as Aby just said, indicating why 11 the 10 mile is the magic mile, 12 MR. GODWIN:

Prudent.

13 CHAIRMAN MOHSENI:

Yeah, we will explain -- maybe 14 Mike, this is -- where it came from, you know, how we agreed

()

15 to have a 10-mile EPZ and why we still continue to believe 16 today, even after Chernobyl, that you have implications 17 beyond, why the plume phase 10-mile EPZ is not an issue here 18 and that we continue --

19 A VOICE:

Focus just on KI or other protective 20 measures.

21 MR. HARDEMAN:

Well, let me ask another question.

22 Wasn't the Commission very specific in its direction that 23 they were limiting the discussion to the 10-mile emergency 24 planning zone?

25 MR. JAMGOCHIAN:

That's correct.

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CHAIRMAN MOHSENI:

That's one factor.

Is that

()

2 enough for the world because the Commission didn't go --

3 MR. JAMGOCHIAN:

Isn't FDA going to evaluate that 4

-- the validity of that 10 miles?

In fact, I'm reading as 5

we were talking this WHO document and it says, "The latest 6

information on the balance of risk will also need to be 7

properly considered in the plans for any di- 'ribution and 8

storage of stable iodine.

It suggests that stockpiling is 9

warranted when feasible over much wider areas than normally 10 encompassed by emergency planning zones".

11 I was very surprised to read that.

12 MR. GODWIN:

I don't see our role here as the 13 defenders of the 10-mile EPZ and I don't think we can -- I 14 mean, that's an entirely separate document, if you will.

()

15 MR. JAMGOCHIAN:

That's going to be up to the 16 Commission.

17 MR. GODWIN:

Yeah.

18 MR. JAMGOCHIAN:

And I think, Jim, you just said l

19 that.

The Commission right now -- it's got a big enough wad 20 to chew on just in the 10 miles.

It's choking on that, 21 so --

i 22 MR. GODWIN:

Let me explain that WHO comment.

23 That was based upon the agricultural considerations that --

i 24 because they did not take protective actions on the milk and 25 agricultural issues in those countries and ultimately they

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had problems in trying to do it because they didn't have

()

2 replacement milk for the essential populations.

3 And if you consider that you might not have milk 4

to replace it, you will have to go beyond the EPZ rather 5

quickly if you feel --

6 CHAIRMAN MOHSENI:

And I don't remember where it 7

was but somewhere in the WHO it said nowhere in Europe are 8

you far enough that you wouldn't need it.

9 That's another difference in our thinking, I 10 think.

They're preparing for a Chernobyl.

We're preparing 11 for TMI plus and that -- what are you --

12 A VOICE:

Do you have a little heartburn with 13 that, Aubrey?

14 MR. GODWIN:

Don't get me started on DOE.

It's 15 time.

16 CHAIRMAN MOHSENI:

We'll meet again tomorrow at 17 8:00.

Was it 8:30?

18

[Whereupon, the meeting was recessed, to reconvene 19 at 8:30 a.m.,

on Tcesday, March 2, 1999.]

20 21 22 23 24 25

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r REPORTER'S CERTIFICATE This is to certify that the attached proceedings

()

before the United States Nuclear Regulatory Commission in the matter-of:

NAME OF PROCEEDING:

POTASSIUM IODIDE (KI)

CORE GROUP MEETING CASE NUMBER:

PLACE OF PROCEEDING:

Tempe, AZ were held as herein appears, and that this is the original

()

transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to 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.

AJb r

g John Hanley Official Reporter Ann Riley & Associates, Ltd.

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