ML20217J156

Summary of 970610 ACRS Planning & Procedures Subcommittee Meeting in Rockville,Md Re Matters Related to Conduct of ACRS Business

ML20217J156
Person / Time
Issue date:	06/12/1997
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
Shared Package
ML20217J161	List: ML20217J156 ML20217J214 ML20217J219
References
ACRS-3063, NUDOCS 9708140031
Download: ML20217J156 (7)

Text

f ., t . . t7du-ss4 9 CERTIFIED fpgf(/j//f7 R. L. Seale, Chmn.

June 24, 1997 June 12.1997

SUMMARY

/ MINUTES OF THE ACRS PLANNING AND PROCEDURES SUBCOMMITTEE MEETING JUNE 10. 1997 The ACRS Subcomittee on Planning and Procedures held a meeting on June 10. 1997, in Room 281. Two White Flint North Building. Rockville Maryland. The purpose of the meeting was to discuss matters related to the conduct of ACRS business.

The meeting was convened at 1:00 P.M. and adjourned at 3:25 P.M.

ATTENDEES R. L. Seale. Chairman D. A. Powers T. S. Kress ACRS Staff J. T. Larkins. ACRS Executive Director S. Duraiswamy C. Harris R. Savio R. Sumers

1. POTASSIUM IODIDE LETTER OF 5/9/97 (0 pen)

In response to the ACRS letter of May 9,1997, on the subject of potassium iodide stockpiling. Mr. Peter Crane, an attorney in the Office of the General Counsel, as a private citizen forwarded a letter to the Comission critical of the position taken by the Comittee. He was particularly critical of the ACRS discussion on side effects and expressed the opinion that the Comittee did not understand that the issue of side effects has been " explored exhaustively over many years." (pp. 1-10)

RECOMMENDATION The Planning and Procedures Subcomittee recommends that the Comittee take no action on this matter.

2) SRM ON MAY 27. 1997 MEETING WITH COMMISSION (0 pen)

The Comission issued a Staff Requirements Memorandum (SRM) on May 27.

1997 (pp.11-12) that in addition to sumarizing the subjects discussed byl at the Comission meeting, also tasked the ACRS to determine the change in I

'C0F and LERF from site to site, when these lower tier criteria are derived O '

from the prompt fatality quantitative health objecthes. The second task was for the Comittee to review the adequacy of the guidance being provided by the staff relative to the use of uncertainty versus point values in the PRA-related decisionmaking processes. After reviewing the SRM. the Executive Director of the ACRS/ACNW spoke with the Chairman's 1.o u .. . U c>W 4Aug 9708140031 970612 v

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Office and noted that it might be more appropriate for the ACRS to perform a limited number of calculations as examples and have th staff 31ck up i

the completion of this task. Additionally. it was not, that_ tie ACRS could work with the NRC staf f to develop improved guidan s on the use or consideration of uncertainty in PRA related decisions. Both suggestions were acceptable to the Chairman's Office. The Committee needs to decide how it wants to handle these two tasks.

RECOMMENDATION The Subcommittee recommends that this issue be added to the agenda for the Subcommittee meeting on July 7,1997 and that Rick Sherry. Senior ACRS Fellow, provide a briefing to the Committee during the June meeting regarding the approach being used to perform the task associated with determining change in CDF and LERF from site to site.

3) ACRS HOMEPAGE AND E MAIL ACCESS (0 pen)

At one time the ACRS maintained an electronic bulletin board (BBS), which was dropped with the availability of E Mail via the World Wide Web (WWW).

Several accounts were made available through IRM contracting with PSINET for member access, which the Agency pays for whether used or not, it would be extremely useful for all ACRS members to have access to the ACRS HomePage and E Mail. This would facilitate forwarding some documents and soliciting member comments on emerging issues. The ACRS Office will cancel this PSINET contract if these services are not being used, but strongly urges members to have internet access at home or office.

RECOMMENDATION The Subcommittee recomends that members notify Ms. Carol Harris if they wish to continue to maintain access to the Internet through PSINET. All members are strongly urged to obtain internet access.

4) USE OF CONSULTANTS (0 pen)

Two ACRS consultants attended a meetin Westinghouse on AP600 licensing issues.gDuring between thisthe NRC staff meeting, the and consultants were drawn into the discussions and provided critical input into the develo Key elements in the staff position would,pment of the staff position.by all appearances, not have evolv consultants' participation. We sought OGC's guidance as to the legal restrictions-on the consultants

• participation-in future ACRS review of the staff The issues and OGC guidance are documented in the enclosed epositions. mail messages from R. Savio to J. Szabo and from R. Savio to P.

Boehnert (pp. 13 15) There are no legal restrictions that would prevent the ACRS consultants from participating in the ACRS review of these staff positions. Clear disclosure of the ACRS consultants

• role in the development of the staff position should be made during ACRS review.

The Planning and Procedures Subcommittee needs to decide whether the ACRS will permit ACRS consultants to be involved in the development of staff or-

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3 industry posicions outside of Comittee meetings. The ACRS has strongly discouraged this type of involvement in the past.

RECOMMENDATION The Subcomittee reaffirmed that ACRS positions are comunicated only through Full Comittee letters and reports. It recomended that consultants be remindc-d to make the distinction in each meeting and comunication that their coments represent their individual views and not the views of the ACRS.

5) ACRS/ACNW FY 1998 2001 BUDGET (0 pen / Closed)

The Executive Director. Deputy Executive Director, and Chief. Operations Support Branch, went before the Budget Review Group on May 19. 1997 and presented the proposed five Year Budaet for the office. Several questions arose concerning the need for additional resources and the out years for DOE Oversight and other activities. Subsequently, cuestions have been asked about the amount of resources needed to assume t1e responsibilities of the NSRRC. An estimate has been forwarded to the Office of the Controller on the level of. resources that will be needed to ad meet the needs of the Director of the Office of Research (quately RES) in providing advice on the Research Program (pp.1617). RES has prepared an options paper for Commission consideration in which a recomendation is made to have the ACRS assume the responsibilities of the NSRRC.

RECOMMENDATION The Subcomittee recomends that the ACRS support whatever decision is made by the Comission regarding NSRRC but that if this responsibility were to be assumed by the ACRS. the Comittee would have to address bhtt, research should be carried out, not just how it is carried out. The Subcomittee also recommends that the ACRS Subcomittee structure be restructured and a new Subcomittee on the Safety Research Program be established.

6) CONCERN REGARDING THE DIRECT CONTAINMENT HEATING (DCH) ISSUE RESOLUTION .

(0 pen)

Dr. T. S. Kress recently' received a letter and a reaort from a former SNL employee concerning NRC s technical closure of tbe Direct Containment Heating-issue. The ACRS forwarded it to the EDO. The NRC Staff is now handling this individual's concerns through the allegation process. RES has the action on the evaluation of this individual's concerns and the ED0 erp 'ts to have a response to the ACRS by mid August 1997. Gus Cronenberg hat viewed this individual's report and will arovide his insights to the Con see. it is our recomendation that the ACRS not take any additional actu.i until we receive the E00's response.

o. -

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4 RECOMMENDATION The Subcommittee recommends that the ACRS take no additional action until a reply is received from the EDO.

7) OUADRIPARTITE MEETING (0 pen)

We received letters of appreciation from Prof. A. Birkhifer. Germany ().

on our bilateral exchange with tie

-18),

RSK. and Bernhard Additionally. Dr.Wilpert.

W11 pert Germany,losed enc a copy of their Memorandum on Safety Culture in the German Nuclear Industry, A letter was faxed to Dr.-Yasumasa Togo, on May 13. 1997, which noted that we agreed to have the Quadripartite meeting in January 19 23.1998, and we ,

needed to reach agreement on an agenda as soon e practical (p. 19).

RECOMMENDATION The Subcommittee recommends that the German Hemorandum on Safety Culture be translated and provided to the ACRS as well as to NRC Commissioners.

8) RESOLUTION OF TECHNICAL ISSUES BEDIEEN INDUSTRY AND NRC STAFF (0 pen)

On May 30.1997. Dr. Larkins received a call from the NRC Chairman's Executive Assistant. Marty Virgilio, with a message from the Chairman that her office and other Commissioners would like to see the ACRS play a more proactive role in the resolution of technical issues between the NRC staff and industry (e.g., AP600 issues. BWR Vessel Weld Examinations). It is difficult for the Commission to be placed in a position of having to reach consensus on technical issues that the staff is unable to resolve with industry, and it would be beneficial to have the ACRS as a facilitator or moderator on these issues and provide its views to the Commission. Dr.

Larkins noted that the Comittee would be more than willing to fill this role, within budget constraints; however, we need to be kept informed in a timely manner of these issues. Dr. Larkins requested and has obtained access to the Chairman's Action Tracking System.

RECOMMENDATION The Subcommittee recommends that the Executive Director meet monthly with

-a representative of the Chairman's and ED0's offices to identify any 4st-minute issues that should be addressed.

9) OVERSIGHT COMMITTEES RECEIVING ACRS REPORTS (0 pen)

. In response to a Comittee request. the ACRS/ACNW Office has reinst1tuted distribution of ACRS letter re) orts to the NRC's Congressional Oversight Comittees.- which include the Committee on Environment and Public Works.

Subcomittee on Clean Air. Wetlands.- Private Property and Nuclear Safety and the Comittee on Commerce. Subcomittee on Energy and Power.

9 5

RECOMMENDATION The Subcommittee recomends that a copy of. the next Annual Report to-Congress on the NRC Research Program also be provided to the Office'of

~ Senator Phil Gramm.

10) STATUS-OF APPOINTMENT OF MEMBERS (Closed)-

The Commission has requested that the ACRS Screening Panel submit another slate of potential ACRS members to the Commission prior to the end of September 1997. Currently, we have no new candidates under active

' consideration. The Executive Director has contacted the Chairman's Office and two Commissioners' offices: however, no assistance or additional '

guidance was offered.

RECOMMENDATION The Subcommittee recommends that the Executive Director review the list of previous applicants to. determine'if an applicant who had applied during the past 2-3 years but had not been chosen might be reconsidered. If no viable candidates are identified in the field of plant operation / thermal hydraulics, a different field of expertise might be chosen,

. 11) BENCHMARK ON RISK DURilG LOW-POWER AND SHUTDOWN OPERATIONS (0 pen)

The staff issued a response dated May 28. 1997, to the ACRS letter of April.18. 1997, stating that "we believe that more detailed benchmarking is not necessary to support a rulemaking on shutdown." This response was attributed to some OGC changes. BNever, the staff revised its response on June 6. 1997, stating that it plans to examine. in more detail, the risk posed by low-power and shutdown operations. The staff plans to gather information for use in decfding-how to proceed in performing any benchmarking of the low power and shutdown operations risk. The ACRS

- needs to develop a schedule to hold discussions with the staff regarding this: matter (see pp. 20-23).

- RECOMMENDATION 4

The - Subcommittee recommends that the ACRS be actively involved -in reviewing further developments in this area.

12). TRAVEL (0 pen) 4 An expedited Travel Request for George Apostolakis to attend the Society for Risk Analysis meeting at UCLA on May 22.-1997 was approved. This

request came in after the meeting in May 1997. -and a one-time special accommodation was made by the ACRS Chairman and Executive Director.

RECOMMENDATION

, . The Subcommittee recommends that this process of the ACRS Chairman's and Executive' Director's approving unanticipated or unplanned travel be recognized as an acceptable procedure.

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,,. May it,1997 TO: Chairman Jackson Pa--a..aana, Rogers Pasasedastanar Diggg Pa==iadw McGaffigan Pa=mlamianae Dias i

FROM:

SUBJECT:

Peter Crene h

ACRS LETTER OF MAY 9,1997 (POTASSIUM IODIDE STOCKPZLING)

On May 9,1997, Chairman R. L. Saala of the Advisory Committee on Reactor Safeguards wrote to Chairman Jackson, preaanting the views of the ACRS on the NRC staff's planned disposition of my petition for rulemaking concerning potassium iodide (PRM-50-G). The letter requires a response from me, I regret to say '

First, I would like to acknowledge, with appreciation, that the ACRS invited me to make a. prenantation at the April 3-4 meeting. Having earlier planned a family vacation iri that week, I did not take the Committee up on its invitation, and instead submitted a written statement, consisting of a latter, my statament to the Maine Advisory Commission on Radiation, and my rulamaking petition. Perhaps if I had been there in person, some misunderstandings might have been avoided.

Having said that, I must also say that the transcript of the April 3-4 session, together with Chairman Seala's letter, leaves me with considerable doubt whether the ACRS majority bothared to read the papers that were before them. The inescapabla impresalon created by the discussion of side affects in the meeting is that at least some members were wholly unaware that this issue has been emplored exhaustively over many years.- (This is, after all, a drug that the Food and Drug Administration approved as safe and effective as long ago as the 1970's.) The Polish szparlance in administering 18 million doses of KI after Chernobyl, and the minimal side affects encountered, have been discussed not only in my own filings, but also by the NRC staff, in its memoranda to the Commisalon of 1993 and 1994. I cannot help thinking that if the majority of the Commission's nationally eminant (and not inaspensive)

Advisory Comadttee on Reactor Safeguards had shown just a fraction of the assiduity and vigor that the Maine Advisory Coramission on Radiation displayed at ita inesting of December 6,1996, the result might have been different.

• As in the past, this latter is written at home, on my own time, in my private capacity, not in my official capacity as Counsel for Special Projects in the NRC's Office of the Ganaral Counsel.

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.. 2 l I wtah I had a videotape of that Maine meeting, to show to the ACRs and l to others as waB. In the weeks since their previous meeting, one member of the Maine Commisalon had researched the Polas' use of KI, including the minimal 4

side effects that were seen, and be made a preaantation based on Nauman and ,

Wolff's aandnal paper (which is discussed in my rutamaWg petition). Anothar '

, member of the Commission reported to the group on his discussions with a prominant thyroldologist from Maina Medical Cantar.

It is small wonder that with this energetic, hando-en approach to lasuas of fact and poucy, Maine was able to bring the K! issue to resolution so quickly. (The State's new policy of stockpuing KI want into affect aarHar this month.) By contraat, the Federal Government continues to fumble ineffectually I with the K! issue. More than half a year has alapsed since the Federal Radiological preparednaas Coordinating Committee (FRPCC) voted to approve a new poucy under which the Federal Government would buy KI for any stata desiring to stockpile it, but no announcement has yet appeared in the E3dagal Reaistar. Indeed, the Federal Government has been agonizing over the KI l

~

issue for more ganga than it took Maine e to research, debata, and decide it.

l I do not wish to rahash the martts of the came once again - only to say

! that Dr. Krass, the dissenting member, has in my view much the battar i argument. Rather, I would like to address the Committee's discussion of the j action of the Ad Hoc Subcommittee on KZ of the FRPCC.

l That Subcommittee was headed by Mr. William McNutt, an honorable and

upright public servant who conducted the group's handling of the KIlasue with l scrupulous fairness and professionalism. In a committee affort, however, where g each member can propose the insertion of this or that aantance, unfortunata

! language can sometimes appear. One aantance, quoted by Dr. Saala in tha l ACRS's lettar, is a case in point. Rafarring to the June 1996 public meeting of l the Subcommittee (at which, ganara11y speaking, au the scientific and medical

{ azparts spoka in favor of KI stockpiling, while lobbyists for industry and a ,

j number of state officials opposed it), the Subcommittee said: l 1

While the viewpoints prenanted at the public meeting l were compelling, the 1996 Subcommittaa heard no new '

. information that eartously chauanges the beams for the 1985 maandation concerning public use of KI. j "No new information" - that is a phrase to gladden the heart of the Nuclear Enargy Institute, which trumpeted it in its unsucceaaful effort to block 4

d 4

l I

a 1

- 3 l* KI stockpiling in Maine.' Any reasonable person reading the aantance just l'

> quoted would naturauy understand it to maan that no new information on KI had come to Mght since 1985, and that the Sukoosunittee was therefore endorsing the

('( asisting KZ policy.

l

! How wrong that person would be! In fact, as Mr. McNutt himaalf would l surely tau you, the phrane actuauy means that no new infonnation had been l l developed einea the BuboeaJnittaa's nrevious amamination of the 4==ue, iust two l

years hafore. in 1994. Between 1945 and D94, however, a vast wealth of new l infonaation on K1 became available, prindpany relating to Charnobyl and the l cardnogenic effect of accidentaUy relaaned rmAininAina on the thyroids of i children.

[

Nor is tisdag the only problem with this artfully worded aantence. Nota l, ,

that it does not say, "no new infonnation regarding KI," but refers instead to "new information that seriously cha11anges the hagga for the 1985 l

recommendation." What were the bases for that recommandation? The principal

! basis was a cost-benefit analysis - in my view, a travesty, as I have amplained l

alaewhere - that purported to prove that KI was "not worthwhile." Whether or

not the cost-benatit analysis was worthless is irrelevant, for present purposes.

The point is that neither I nor the NRC staff, in its 1994 recommandation to the Comuniasion in favor of stockpiling, nor any of the other advocates of KI, so far as I know, is arguing that KI is " cost-effective," in the sense of being likely to j pay for itself in the long run. Rather, the argument for KI is that it is i

cheap, effective, and highly desirable from the standpoint of prudence.

) Thus it is possible to say that the " bases for the 1985 receaunandation" have not been challenged, if by that you maan that the 1985 recommandation lg was based on cost-effectiveness, and that the prenant-day advocatas of KI l

l stockpiling are not arguing that it is on grounds of cost-effectivansas that the j drug should be stockpiled. But the effect is not to add to gnblic knowledge l

and undarstanding, but rather to pull the wool over its eyes. I sincerely hope i that no more public currency wiu be given to this mariously adalaading l

aantance. The Amartcan people deserve better from their Government. ,

l cc: Advlacry Comunittee on Reactor Safeguards

Executive Director for Operations i General Counsel i Winian McNutt, FEMA Docket File (pAM-50-43) i

Attachment:

Istter to the ACRS, March 24,1997 (w/o enclosures)

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'It is not my role to tan NE! how to run its buainaam, but I find its myopia ,

' on the K! issue unfathomable. In Canada, the nuclear power plant operators  !

believe that KI stockpiling is good pubMc relations. In the U.S., by contrast, i' the industry has taken the position that stockpiling KI could undermine public confidence in nuclear power. Senators Alan Simpson and Joseph Lieberman '

disposed of that argument in their lettar to the Camadastan of Apstl 20,1994.

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.- March 26,1997 MEMORANDUM FORT The Advisory Committee on Reactor Safeguards FROM Peter Crane h e_

SUBJECT:

POTASSIUM 10DIDF, (KI)

I very much approdata the opportunity to prenant my views to the Committee.

Because I have not seen the proposal that the NRC etaff will be preaanting to the Committee, I cannot comment on it, but will instand addreas the potassium lodida lasus generally. Having dealt with the K1 issue at langth elsewhere, however,1intand to keep this memorandum short. I would ask the members of the Cosedttee to consider two attached documents, which I incorporata by reference. The first is the petition for rulemaking that I filed with the

- Commission in September,1995. The second is a document prepared for a December 6,1996 meeting of the Maine Radiation Advisory ea==i==4an. (My presentation to that commission was oral, and there was no necessity of submitting the prepared taat.)*

The asisting federal K1 policy dates from the summer of 1985, nine months before Charnobyl. In October and November 1995, I wrote to James Lee Witt, Director of the Federal Emergency Management Agency, pointing out serious problems in the Federal Radiological Emergency Respow Plan, and enclosing a copy of my rulemaking petition. In response, Mr. Witt reconstituted the Ad Hoc Subcommittee on Potassium Iodide (which had been on the point of reaffirsdng the 1985 policy) and asked it to consider my rulemaking petition and g my 1sttars to him. The result, confirmed unanimaualy by the full Federal

. Radiological Preparedness Coordinating Committee on October 24,1996, was, in the words of a FEMA official, a "new Federal policy of offering to fund a K1 stockpils for thoaa States who hereafter decida to include its use as a protective measure for the general public."' Almost five months after the FRPCC's

' At the December 6 meeting, the Maine Commisslan voted unanimously to recommand to the Governor that tha Stata stockpile KI at the three reception centers in the vicinity of the Maine Yankee nuclear plant. The next day's -

Portland Prasa-Marald quoted one of the Commission's members, Donald Hozia, a .,

former head of Maine's health engineering division, as saying: " Ten years from now, if we have a release, I would rather any that we [ erred) on the side of conservattaa, knowing what we know." The members of the ra==4==4aa indicated at the meeting that they were particularly impressed by the commente of Dr. Jacob Robbins of the NationalInstitutes of Health, whose latter summarizing the arguments for KII read aloud at the conclualon of my talk.

• Letter of March 5,19g7, from MaIy C. Goes, FEMA Associate Director for Preparedness, Training and Esercises, to Peter Crane. It appears as Inclosure 3 to thia paper.

l

.- 2 decision, however, the States and the puhuc have yet to learn of the nm poucy, because no Federal Register notice has been published.- According to the same FEMA official, this is because the NRC and FEMA are " arranging the administrative details" to support the new poucy.

1 4 It might seem self-evident that when the Federal Government decides to abandon a poucy that unas the phrase "not worthwhila" with regard to KI, in favor of a new poucy of paying for stata stockpilas, something has changed, presumably because something new has been learned. Neverthelaas, even today, whenever the K1 issue is debated, the defenders of the 1985 policy can be counted on to repeat the refrain that there is "no new data" impugning it.'

There are two problems with this claim. The first la that it is flatly, demonstrably untrue. For azample, in 1983, when the Federal Government was

, formulating the esisting policy, it was stiu possible for Shlalan, Malperin et al.

of the Food and Drug Adadnistration to writa *There is a paucity of human data relevant to the induction of radiation effects from lodine-131, particularly in children."' Sad to say, this is no longer the case; as the literature attesta, Chernobyl has produced all too much new information on this subject.

Likewise, Shleian et al. reported disagreement on the safety of administaring KI, mentioning in particular Yalow's predictions of advaram affects.' On this J lasua, there is now aztensive probative data, documented in Nauman and Wolff's paper on the Polish esparlance in administering 18 million dogas of K1 with minimal adverse reactions.

The second problem with the claim of "no new data" is that the asisting policy was fatany dafective from the start. Thus even if it were true that there is

( "no new data" today beyond what was available to the Government in 1985, this would be irrelevant a policy change would stiu be appropriata, because the

• As I wrote to Director Witt in lata December,1996: "The Subcommittee's recommandation was voted on by the fun FRPCC on October 24, more than two months ago. Rightly or wrongly, a lobbyist for the nuclear industry has since proclaimed a " win-win" for the industry position, and even assertad that no new technical information has developed since the asisting KI poucy was put in place in 1985. (In reality, the most algnificant single data point is the epidemic of childhood thyroid cancer in the former Soviet Union, caused by the 1986 Charnabyl acciaant.) How can such claims be made? Because the public and -

the industry have yet to haar word one from FEMA about its resolution of the KI lasua."

• "Recommandations on the use of potassium lodida as a Thyroid-Blocking Agent in Radir. tion Accidents: An FDA Updata," 3. Shlaien, J. Halperin, J.

Rilstad, P. Sotatsin, E. Dutra, at p. 5. This paper was before the Commission at the thee that the current K1 poucy was being devaleped. It appears as Enclosure D to SECY-43-362 (Aug. 30,1983).

• M. at 2-3.

l

l-l 3 1985 polley was based on a adacharacterisation of the data than available.

l The flaws in the 1985 policy (which remains the current policy, while we i

continue to wait for FEMA's Federal Register notice) were plainly observable

' even before it was adopted. For example, the linchpin of the NRC staff's argument agahst K1 in 1983, when the tasue was preaanted to the Commission j for decision, was that it was not cost-effective, when the rarity of estare accidents was factored in. However, the ACRS Subcomunittee on Reactor Radiological Effects abaarved at the times The risk / benefit analyses conducted by the NRC Staff en this subject do not appear to be compatible with (or comparable to) approaches used in evaluating other l aspects of nuclear amargency planning. For example, if the same evaluations were made, would there be any i

i justification for the conduct of esaargency drills or the l installation of warning a1rens7

• No antisfactory answer to the ACRS's comment was offered than or later.

l A review of the record of what occurred on the K1 issue between 1979 and 1983 suggests that the cost-benefit balancing that was used to disparage the value of K1 to the Commissioners in 1983, and that provided the rationale for the current l U.S. policy on KI, was a post hoc rationalisation for a declalon already made on l

other grounds. The record includes the followings l

- In 1979, the President's Commission on the Accident at Three Mila li Island (Kamany Commission) criticizes the failure to stockpila KI, and recommanda the creation of stockpiles; the NRC, later the same year, endorses the Kamany recommartdation and declarse its intention to maka KI a licanaing requirement.

- Between 1979 and 1982, the relevant federal agencias move forward with plans for the implementation of the Kamany recommandation, f

-In Septosaber,1982, the NRC staff submits a meum to the Commission (SECY-42-396) asking it to approve an intaragancy l policy statament (already approv.a formally or informally by FEMA, DOE, EPA, FDA, and USDA) which says, among other things, that l "where shaltar is used because the evacuation cannot be completed l

in time to avoid a substantial radiation insult, the adadaistration of K1 could be a useful ancillary protective action which could provide

• " Comments on the Use of Potassium Iodide (KI) as a Thyttdd Blocking Agent," April 30,1983. It appears as Attachment 1 to Enclosure D of SECY-43-362.

4

• eome additional exposure reduction to the thyroids of asposed individuals." ,

- In October,1982, the NRC staff, in SECY-42-396A, withdraws the paper subadtted just la days before. The new paper statast l 1 am now informed by our Office of Research that in - ,

light of the information available on the behavior of I

1 radiciodine during reactor accidents, a technical paner j

e,hhh eenld ahaw that the u== af na+==-8um indida for j

tha ;;naral nublic is aieniMeantiv laan eest hanafiM i

thattareviouaiv assumed gould be nroduced by January 1, 1983. (The previous study sponsored by the Office i of Research, NUREG/CR-1433, March 1980, concluded i

that the distribution of potassium todide to the general public was "only marginally unst-effective, at best.")

i In view of this infusaation, I am withdrawing the staff 4

proposal contained in SECY-42-396. When the Office of Research paper is complete, I will aand it to the other l Federal agencias involved with a recommandation that a neliev statement recommandino maainst the stockniline i and Matribution of notamatum indida, for the general

! public be developed.

! The Commission should also be aware that TEMA has

! recentiv ravarmed its nravisua dadmion ta nurebana a r

laram cruantity of ne+amatum todida for a national

!I stockpile. [ Emphasis added.)  ;

' Nothing in the October 1982 paper indicated that any new information on K1 had

. been obtained during the preceding 21 weeks - apart from the central fact that l 4

the Executive Branch had just reversed direction on K1, for remnana not stated I in the paper - yet it was already able to state what the cost-benefit analysis 1 i

l would find, and what the NRC's recomunendation to the other federal agencias would be.

! Before concluding, I note that the Cenittee wlIl be hearing presentations from two gentlemen whom I had the pleasure of meeting last sununer at FEMA, at the l June 27,1996 meeting of the FRpCC Ad Noe subcommittee on potaastus lodida ,

Mr. Alan Nelson, of the Nuclear Energy Institute,and Mr. Roy Wight, of the  !

j Illinois Department of Nuclear Safety. At that time, both argued strenuously

.sgainst any change in the 1985 K1 policy. I would like to address some of the i

points they made at that meeting, on the assumption, perhaps not correct, that

, their arguments to the Comn.ittee will be along the same lines as the views they i espressed last summer. If in fact their views have changed since that thee, I and I am addressing myself to positions they no longer hold, I apologise. l l

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!' The nub of my argument was that officials coping with radiological amargencies

- abould have three tools at their disposal, to use singly or in combination as particular drcumstanens might dictate or permit: evacuation, shaltaring, and potassium lodida. The nub of Mr. Nelson's argument, as I understood it, was that potassium lodide is not needed. maaking clarification of his position,1 I asked the following questions' MR. CRANE: It is a question for Alan, which ist It

esens to me, if ever we've got an event in which K1 is needed, there are going to be a lot of people reading the transcript of this meeting. So I think it's good to be clear about one point. I understand what you're basically saying is, "We don't need this because evacuation works and evacuation is bottar." And what i 1 would Eka to know is

Are you talling us on behalf of the industry that for every credibla uddent, i

completa evacuation of the affected population, apart

from shut-ins and prisoners, is not only feasible but can be guaranteed?

l MR. A. NELSON: I'm not sure it's my place tn maka l

that statament. The states and locals are prepared to

! implement plans based on recommandations and data i that they have as precursors to events, precautionary i measures that they take early on. It's not as simple l aat can you do these things as a guarantae of a lot of .

! things?

!l i As we have improved our amargency p.eyse'r---

activities, amargency response data system is I available, states are monitoring utilities, the NRC has their operations contar and regional operation contar to

} monitor the nuclear power plants. Safety systems have l

been improved, in spite of some of the points that were mentioned, where reactor operations and containment l can be observed. Meteorological data, does assessments are taking place at the same time.

I' Confirmation of protective actions early on may be j implemented.

i I think that we have improved our emergency plans to a point long after TMI. The same Kamany position that was agtahMahaA back in ig?9-19go, if evaluated today,

' This is the verbatim transcript, pages 203-04, with only punctuation i corrected.

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one would ano that there has been a great deal of i* improvement in emergency preparednaas.

I think that the adequacy of the public can be

!* ; protected. And I think that the programs that we have sta in the state and local azarcians and real

events have barna that out.

! I bdieve that this non-responsive answer, in which the word " evacuation" is a mot even mentioned, speaks vehumas.

Mr. Wight, in his prepared statement to the June 1996 meeting, said:

l It is also recognised that although the thyroid performs a nacaseary bsological functson, the naas of j

the thyroid gland is not life-threatening and can be i overcome with appropriate medication.'

l l Before going any further, let me say that I am not impugning Mr. Wight's

it.tegrity or the sincerity of his desire to do what is right for the people of his i

s':sta. I would suggest, however, that his statament at the June meeting, if I understood it correctly, reflected incompleta knowledge about thyrotf. diamaae.

i The most recent projection of the American Cancer Society, as a talet hone call j grill confirm, is that about 16,000 Americans will be diagnosed with thyroid

tancer in 1997, and about 1200 will die of it. Thus although the loss of the

! thyroid is not hfe-threatening in itself - one can taka medication to asplace the hormone produced by the gland - the cancer that s33333 the naas of the j( thyroid is fatal in a amau but significant parcantage of casas, and has tartous impacts on the quality of life in a much larger percentage.

! At the June 1996 meeting, Dr. Jacob Robbins, an endnant thyroid cancer

- specialist at NIH, had this to say when asked to comment on Mr. Wight's statement and on the actual consequences of the diamaae 1

That is sort af hard to answer, but if you think of car.m in ganarel, if you were going to have a pl- cancer, it wouldn't be bad to have a thyroid cancer.

The mortality is now. And even in the children, whost 4

we've heard have very aggresalvely growing thyroid j

I ' Statement by Roy R. Wight, p. 2. Quite aimilar language appeared in the prepared statement of Sandra J. Threatt of the South Carolina Department of Health and Environmental Control 'The thyroid performs a necessary l biological function. However, loss of the thyroid gland is not life-threatening

! and can be medicauy managed.' At p. 2.

l*

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', cancers, the mortality is a few percent. .

But we have to remember that the children that were esposed who haven't had cancer yet are not free of the risk of getting cancer. So when they become adults,

.I they can still get thyroid cancer. And then the risk -

gets higher, perhaps tan percent. We heard the number before.

So there is a stak of mortahty. So for the individual who has the dissaae, mortality risk is now. It's treatable. But the treatment requires not only an tamediata operation but Efetime surveillance, medication, the possibility that they wol require radioactive lodina therapy repeatedly.

. It's a significant medical Gansas. It's not a trivial G1 ness. I think that's au that we need to any about it.'

Again, I do not mean this as an attack on Mr. Wight or the Government of Illinois. If today, any statas are stG1 under the impression that thyroid cancer is too txtvial an illness to be worth preventing, that is less a recaction on them than it is on the Federal Government, which for some 15 years has failed to Mvs up to its responsibility to provide the states with accurata and complate information on this subject.

If there are any supporting documents that would he helpful to the Committee, I

( would be happy to supply them, as wou as to answer any questions that the Committee may have. Thank you.

Enclosures:

A. Rulamaking petitiae (September 1995)

5. Statament to Maine Radiation Adytacry Cawandantaa (hh- 1996)

C. Letter from Ray C. Goss, FEMA (March 1997)

' Trenacetyt at 167-48.

See the AprG 20,1994 letter to Chairman Salin from Senatore Alan Simpson and Joseph Lieberman (attachment to the 1995 rulamaking petition).

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@ May 27, 1997

.IN MESPONSE, PLEASE REFER-TO: M970502A i

800AffA#f 4

MEMORANDUM 70: John T. Larkins Exec ie r ctor, ACRS FROM: Jo C. o e, Secretary

SUBJECT:

STAFF REQUIREMENTS - MEETING WITH THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS), 9:00 A.M., FRIDAY, MAY 2, 1997 COMMISSIONERS' CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE)

.The Commission was briefed by the ACRS on the following topics:

1. (a) Risk-Informed, Performance-Rased Regulation and Related Matters (b) Risk-Based-Regulatory Acceptance Criteria for Plant-specific Application of Safety Goals

2. Proposed Regulatory Approach Associated with steam Generator Integrity

3. Low-Power and Shutdown Operations Risk

4. Status of ACRS Review of National Academy of Sciences /

National Research Council Phase 2 study Report on Digital Instrumentation and Control Systems

5. Human Performance Program Plan

6. ACRS Report to Congress on Nuclear Safety Research and Regulatory Reform The Commission encouraged the ACRS to continue to provide its perspectives on issues important to the mission of the NRC, and to be forward-looking in bringing developing concerns to the Commission's attention in order-to help ensure the NRC is prepared for future challenges. In particular, the Committee's work on acceptance criteria for plant-specific safety goals, and on deriving lower-tier acceptance criteria, is important for consistency and traceability. Specifically, the Commission requested that.the ACRS determine the change in CDF and LERF from site to site, when these lower-tier criteria are derived from the

_ prompt fatality quantitative health objectives.

(ACRS) (SECY Suspense 9/26/97)

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g.uw er am

2-Tho C:mmissicn 01so-cnccurag0d the ACRS to review tho cdaquacy of tha guidance being provided by the staff relative to the use of uncertainty versus point values in the PRA-related decision-making processes.

(ACRS) (SECY Suspense 9/26/97) 4 cc: Chairman Jackson Commissioner Rogers Commissioner Dieus Commissioner Diaz .

, Commissioner McGaffigan EDO OGC CTO CIO OCA 01G Office Directors, Regions, ASLBP (via E-Mail)

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