Public Citizen Advocates Potassium Iodide

[Lisa Marina Brooks <lbrooks@Citizen.Org>]

  On June 27th, Public Citizen's Critical Mass Energy Project participated
  in a public meeting concerning the federal policy on the purchase and
  stockpiling of potassium iodide for use by the general public in
  radiological emergencies at commercial nuclear power plants. Potassium
  Iodide is an inexpensive non prescription drug that would protect the
  thyroid gland from radioactive Iodine 131 released during a meltdown. 
  
  There were a total of 14 individual or organizations that presented
  comments to the Federal Radiological Preparedness Coordinating Committee. 
  Only 5 of the 14 presenters were in favor of providing potassium iodide to
  the public in the event of a severe accident at a nuclear reactor.  The
  representatives of the nuclear industry and of state emergency planning
  agencies all opposed stockpiling potassium iodide.  The states are afraid
  of liability problems involved with disbursing the drug.  The Nuclear
  Energy Institute and Duke Power, a nuclear utility, claimed their reactors
  were safe and potassium iodide was not needed. 
  
  Public Citizen supports the stockpiling and pre-distribution of potassium
  iodide to those within a 50 mile radius of a nuclear reactor.  If you
  would like more information on the meeting or on potassium iodide in
  general you can e-mail Jim Riccio at jriccio@mindspring.com or call
  770-451-7372.  The docket of this meeting is open until July 12th so
  groups and individuals can still submit comments.  Citizens should also
  contact their respective state emergency planning offices and demand that
  they stockpile potassium iodide. 
  
  
  Comments of Public Citizen's Critical Mass Energy Project
  
  Before the Federal Radiological Preparedness Coordinating Committee's
  
  Ad Hoc Subcommittee on Potassium Iodide
  
  June 27, 1996
  
  
  Good Morning.  My name is James Riccio. I am the staff attorney for Public
  Citizen s Critical Mass Energy Project.  Public Citizen is a consumer
  advocacy organization founded by Ralph Nader in 1971, Critical Mass was
  founded in 1974 to address the dangers posed by nuclear reactors and the
  long lived radioactive wastes they produce. 
  
  Public Citizen has long advocated the stockpiling and distribution of
  potassium iodide (KI) to populations living in a 50 mile radius of all
  commercial nuclear reactors. The long standing failure of the Nuclear
  Regulatory Commission (NRC) to require all commercial reactor licensees to
  provide KI to surrounding populations is a disgrace.  The nuclear industry
  and its lobbyists have successfully quashed previous attempts to require
  the stockpiling and distribution of KI.  The NRC has acquiesced to
  industry pressure much to the detriment of the public health and safety. 
  
  The industry's argument that stockpiling and distribution of KI would
  unreasonably raise the fears of the public, is both specious and self
  serving.  The public is already well aware of the dangers posed by nuclear
  reactors.  Providing an additional level of radiation protection in the
  event of an accidental release will not unduly raise the fears of those
  who already live in the shadows of nuclear reactors. 
  
  In the aftermath of the partial core-melt accident at Three Mile Island,
  the NRC acknowledged that safe siting and design-engineered features alone
  do not optimize protection of the public health and safety.  The NRC added
  that although emergency planning had previously been considered a
  secondary and additional means of protecting the public, its perspective
  had been, "severely altered by the unexpected sequence of events that
  occurred at Three Mile Island." (44 Fed. Reg. 75167) The Commission
  concluded that, "the protection provided by safe siting and engineered
  safety features must be bolstered by the ability to take protective
  measures during the course of an accident." (44 Fed. Reg. 75169). 
  
  The President's Commission on the Accident at Three Mile Island, known as
  the Kemeny Commission, was highly critical of the failure to stockpile KI. 
  Among the Kemeny Commission's major recommendations was that an adequate
  supply of the radiation protective agent, potassium iodide, should be
  available regionally for distribution to the general population and
  workers affected by a radiological emergency.  (60 Fed. Reg. 58257). 
  While the NRC endorsed the Kemeny Commission position in 1979 when it was
  released, the Commission has taken no steps to ensure its implementation. 
  
  The Commission has already recognized that in the event of an accident,
  potassium iodide could prove effective and useful under certain
  conditions. Therefore, the NRC's unwillingness to implement the Kemeny
  Commission recommendations regarding the stockpiling and distribution of
  KI is an abrogation of the Commission's statutory responsibility to
  protect the public health and safety. The decision by former Commissioners
  DePlanque and Remick to block the stockpiling and distribution of KI can
  not logically be supported. 
  
  The cost-benefit analysis upon which the current policy is based relies on
  unrealistic assumptions about the probability of severe accidents.  The
  probabilistic risk assessment which underlies the cost-benefit assumptions
  concludes that a severe accident could occur only once in 1000 years.
  However, the NRC has acknowledged that severe accidents might be 100 times
  more likely.  Shortly after the 1986 Chernobyl disaster, NRC Commissioner
  James Asselstine testified to Congress that there was a 45% chance of a
  severe core meltdown at a commercial nuclear reactor within twenty years.
  (James K. Asselstine, Testimony before the Energy Conservation and Power
  Subcommittee of the House Committee on Energy and Commerce, May 22, 1986.)
  
  However, we need not rely on probabilistic analysis.  The history of
  severe accidents at U.S. reactors reveals that the NRC's PRAs are overly
  optimistic. Rather than one severe accident in 1000 years, America's
  nuclear experience includes five partial core melt accidents in 40 years.
  Reactors which have experienced partial core melts include:  EBR-1 on Nov.
  29, 1955; WTR on April 3, 1960; SL-1 on Jan. 3, 1961; Fermi 1 on Oct. 5,
  1966 and Three Mile Island 2 on March 28, 1979.  In light of this fact,
  the Commission's reliance upon PRAs to obviate the need for stockpiling
  and predistribution of KI is at best specious and at worst constitutes an
  abrogation of NRC's statutory responsibility to protect the public health
  and safety.  The intransigence of former NRC Commissioners, in light of
  the staff's support for rewriting NRC's policy on KI, is incomprehensible. 
  It reveals that the NRC and the nuclear industry have learned little from
  the costly accidents at TMI and Chernobyl.  A decade and a half after
  Three Mile Island, the findings of NRC's own Special Inquiry Group still
  hold true. 
  
  The NRC...treats radiation protection as secondary in importance to
  production (of electricity).... The NRC safety reviews have been hardware
  oriented.  The focus of those reviews has been on equipment and
  engineering safeguard features to mitigate and safeguard against
  accidents. As a result, the belief that "accidents can't happen" has
  colored the agency's approach to radiation protection....We find that the
  attitude that radiation protection was of secondary importance was held by
  the NRC. 
  
  (J. Rogovin et al., Three Mile Island: A Report to the Commissioners and
  the Public, U.S. Nuclear Regulatory Commission, January 1980.)
  
  Although many licensees have KI on site to protect their workers, we know
  of only one state that has actually stockpiled and pre-distributed KI for
  public use in the event of an accident.  The State of Tennessee stores KI
  at strategic locations and will distribute upon request to people within a
  five mile radius of a reactor site.  Tennessee also issues KI to those
  residents within the 10 mile EPZ who volunteer to come and get it.(U.S.
  Nuclear Regulatory Commission, Safety Evaluation Report related to the
  operation of Watts Bar Nuclear Plant Units 1 and 2, Dockets 50-390 and
  50-391, SSER 13, April 1994, p. 13-13). 
  
  While several other states (Alabama, Arizona, California, Kentucky,
  Michigan and Vermont) have "plans" to distribute KI to the general public,
  the efficacy of these plans is questionable.  Potassium Iodide is most
  effective if administered prior to radiation exposure.  Seemingly, this
  would make pre-distribution of KI imperative.  The tragic comedy of errors
  surrounding the attempts to distribute KI in the wake of the Three Mile
  Island accident only serves to highlight the need for pre-distribution. 
  
  Stockpiling and pre-distribution of potassium iodide would bring U.S.
  policy into line with what has become an accepted practice among many
  nuclear nations since the Chernobyl accident.  Furthermore, it would help
  provide an equal level of radiation protection to all U.S. citizens
  residing in the vicinity of a nuclear power plant. 
  
  The Commission has already concluded that siting and design are not enough
  to protect the public in the event of a nuclear accident.  The Commission
  and almost all experts acknowledge that potassium iodide can be an
  effective ancillary protective action if taken during a nuclear power
  plant accident.  However, the NRC does not require stockpiling or
  predistribution of KI so that it could be made available to provide
  protection to members of the public.  This logical inconsistency can no
  longer be tolerated. 
  
  The NRC's obfuscation and delay in implementing the Kemeny Commission
  recommendations to stockpile and distribute potassium iodide constitutes
  an abrogation of the Commission's statutory responsibility to protect the
  public health and safety.  I hope that this committee will act
  expeditiously to remedy this unacceptable situation.  I thank you for your
  time and consideration. 
  
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