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Re: The NRC's "Fighter Jet Rule" on KI
What an excellent summary of the issue and argument in support of your position. I don't know much about the issue, although I have read about it in the trade press, but you make a compelling case.
Jim Kennedy
>>> Peter Crane <pgcrane@erols.com> 09/13 8:40 AM >>>
Officially, today is the last day to submit comments to the Nuclear
Regulatory Commission on its proposed rule on potassium iodide in
emergency planning. However, the NRC will consider comments submitted
after today "if it is practical to do so," which in reality means that
commenters have some time to comment. I urge Radsafers to consider
making their voices heard, the sooner the better.
Governments throughout the developed world recognize that the major
health lesson learned from Chernobyl is the extreme sensitivity of
children's thyroid glands to radioiodines: thus the upsurge of
childhood thyroid cancer in Belarus, Russia, and Ukraine. In Poland, by
contrast, health authorities gave out 18 million doses of KI, and
protected virtually all of the nation's 10.5 million children. Polish
authorities believe that the prompt administration of KI is a major
reason that Poland has been spared a similar increase in thyroid cancer.
In the summer of 1998, I spoke to an international conference on
"Radiation and Thyroid Cancer" at Cambridge University. One of the
speakers made the point that virtually all the thyroid cancers appearing
in the former Soviet Union are in children who were four years old or
younger at the time of the accident.
Let me be up front about my own reason for becoming involved in the KI
issue. In the late 40's, when I was two or three, I was among the 4000+
children who received radiation to the head and neck at Michael Reese
Hospital in Chicago for enlarged tonsils and adenoids. At 26, I first
had thyroid cancer, and when I was 42, it recurred, requiring five
courses of I-131 treatment (700 millicuries) before I finally got a
clean bill four years later. I'm well aware that thyroid cancer has a
high cure rate, and that there are many worse diseases one can have.
But I also know from experience that it is not something that you would
wish on your children or yourself.
Americans tend to assume that public health protection for their
children is second to none. In the case of KI, this is not the case.
Twice in 20 years the NRC has made commitments to the American people on
KI, only to renege on them afterwards. As a result, we are still in a
pre-Three Mile Island state of preparedeness on KI, when the drug is
routinely stockpiled (and in some countries predistributed to individual
houses) in many European countries, including France, Germany,
Switzerland, the UK, Sweden, Norway, Austria, the Czech Republic,
Slovakia, Poland, etc., plus Japan and Canada. In my talk to the
Cambridge conference, I laid out the 20-year history of the NRC's
mishandling of the issue; it may be found on the NRC's rulemaking
website, ruleforum@llnl.gov.
The first commitment came in 1979. During the TMI accident, at a point
when a major release of radioiodines was feared, federal and state
officials looked for supplies of KI (which had been declared "safe and
effective" for radiation protection by the Food and Drug Administration
the previous year) and discovered that none existed. An FDA official,
Jerome Halperin, made a midnight call to a drug company executive, who
started up the production line at 3 a.m., with the result that the
first supplies of KI arrived in Pennsylvania 24 hours later.
Fortunately, the accident was brought under control without a major
release, and the drug was not needed.
After the accident, the Presidential commission headed by Dr. John
Kemeny castigated the NRC's failure to ensure adequate stockpiles of
KI. The NRC agreed with the criticism, in a document published in
November 1979, and declared that it intended to require supplies of the
drug to be established near every nuclear plant, as a part of emergency
planning. In 1982, the NRC staff recommended to the NRC Commissioners
that they approve a draft federal policy statement favoring the
stockpiling of KI. Only three weeks later, the NRC staff reversed
itself, withdrew its earlier recommendation, and said that it could
produce a new memorandum asserting that KI was less "cost-effective"
than previously thought.
On November 22, 1983, the NRC staff briefed the Commissioners and the
public on KI. The gist of its argument was that KI was not
cost-effective: that it would be cheaper in the long run not to buy KI,
and spend the money thereby saved on treating any thyroid disease that
might result from not having the drug. The transcript shows NRC
Chairman Nunzio Palladino objecting that if he survived an accident
because of having taken KI, he would think the $.20 or whatever the drug
cost to be money well spent. The staff briefer assured him that
"surviving is not the question." Rather, the issue was one of "averting
an illness," one that involved "a few days' loss." Cancer was never
mentioned; instead, the briefers talked of "nodules." No one listening
to the presentation would have imagined that 40% of the nodules would be
cancerous, or that 5 to 10 percent of the cancers would be fatal.
For more than 10 years, I have been saying, in writing, that the staff
misinformed the Commissioners and the public on that occasion, by
seriously understating the consequences of radiation-caused thyroid
disease. For more than 10 years, the NRC has steadfastly refused to
examine whether or not that is the case. At a Commission meeting on KI
in November 1997 -- the first such meeting in 14 years -- Commissioner
Ed McGaffigan asked the staff what its response was to the charge of
misinformation. The staff's response was that it "had no answer."
In 1989, after the NRC staff declared that the Chernobyl accident was
not grounds for altering course on KI, I filed a "differing professional
opinion" urging that new information called for stockpiling KI, and that
in any case, the existing policy was defective, as it was based on
misinformation to the Commissioners and the public. (I am a lawyer for
the NRC, but this message, like my other work on KI, is written in my
private capacity, at home, on my own time.)
In 1994, the NRC staff sent a memorandum to the Commission that
recommended stockpiling of KI as a "reasonable and prudent" measure,
adding that it was so cheap, at just a few cents a pill, that it would
cost less to stockpile the drug than to go on studying whether the drug
was worthwhile. But the Commissioners split 2-2, and under NRC rules,
that means the status quo stays in place.
In 1995, therefore, I filed a petition for rulemaking, asking that the
NRC make KI stockpiling, along with evacuation and sheltering, part of
its emergency planning rules. At the same time, I wrote to the Federal
Emergency Management Agency, pointing out the flaws in current U.S.
policy on KI. FEMA acted swiftly, and the result, in 1996, was that the
Federal Radiological Preparedness Coordinating Committee, chaired by
FEMA, recommended a new federal policy, under which the U.S. Government
would provide the drug at federal cost to any state requesting it. On
July 1, 1997, the NRC announced that it supported the draft policy, and
declared explicitly, "The NRC will provide the funding."
On November 5, 1997, at the NRC Commission meeting referred to earlier,
I made a tactical decision -- foolish, in retrospect -- to offer a
compromise, because I could see that my 1995 petition was headed to
another 2-2 defeat. I said I would accept a strong recommendation in
favor of stockpiling, coupled with a requirement that states "consider"
KI in their emergency plans, because when this was joined with the offer
of federally-funded KI, no sensible state would turn the offer down.
Elements in the NRC staff remained passionately opposed to KI
stockpiling. In support of a recommendation against stockpiling, they
prepared a document, given the number NUREG-1633, which purported to be
a technical analysis of the drug. One might have thought that the
starting point would have been the FDA's 1978 declaration that the drug
was "safe and effective." Amazingly, NUREG-1633, in all its 40 pages,
never mentioned that fact. Instead, it included dire warnings of severe
side effects of KI, gleaned from the pages of the Physician's Desk
Reference. What no reader could have imagined was that those quotations
did not refer to KI in the low doses used for radiation protection, but
for a prescription-only drug, orders of magnitude more concentrated,
used for certain pulmonary illnesses. After searing comments from the
health departments of New York and Ohio, the NRC Commissioners ordered
NUREG-1633 withdrawn. It was also taken off the NRC website. Eager to
save face, the NRC staff explained that it was being revised in light of
the "many useful comments" received.
In 1998, the NRC reaffirmed its commitment to federally-funded
stockpiling, and in September of that year, sent FEMA a draft Federal
Register notice that would announce the new policy. But in October, the
NRC got a new Commissioner, Jeffrey Merrifield, a young staffer to
Senator Bob Smith of New Hampshire, who has been in the news in 1999 for
quitting not one but two political parties. Commissioner Merrifield
told his colleagues that if he had been at the Commission when the KI
decision was made, he would not have approved it, and he set out to
overturn the Commission's decision.
The result, in April 1999, was that the NRC reversed its position on
funding of state stockpiles. (As to its past position, the NRC would
acknowledge only that it had said in the past that funding for state
stockpiles would "probably" come from NRC; the statement in the 1997
press release that the NRC would provide the funding was passed over in
silence.) Instead, the NRC would support federal funding of REGIONAL
stockpiles.
Regional stockpiles of a drug that needs to be given before or just
after exposure to be useful? The World Health Organization has said
that the drug should be kept locally, in schools, hospitals, fire
stations, and the like. The time spent transporting the drug from
regional stockpiles to the area of need is time lost getting the drug
into the children who need it, and it cannot fail to translate into
increased numbers of childhood thyroid cancers in the event -- the
unlikely event, to be sure -- of a major accident or act of terrorism.
Commissioner Merrifield had an answer to this, however. In an interview
with the Keene (N.H.) Sentinel, he suggested that the drug could be
brought to the area of need by "fighter jet."
Consistent with this approach, the NRC issued a proposed rule in June.
It will require states to "consider" KI, but suggested that many had
already done so. It included no recommendation that states stockpile.
As to funding, it explained that the NRC had to deal with a declining
budget, and that it did not have funds left over for "new initiatives."
It is indicative of how badly the NRC has failed to inform the public
and the states on the KI issue that at a public meeting at FEMA in 1996,
an official of a large and populous state declared one reason for his
state's opposition to KI stockpiling: that "Loss of the thyroid is not
life-threatening." (When I criticized this statement in comments to the
NRC, a more senior official of that state angrily responded that
"hundreds of thousands of people live normal, healthy lives without
functioning thyroid glands.")
The American Thyroid Association has been pleading since 1989 for a more
enlightened policy on KI. The World Health Organization is moving
toward recommending more aggressive intervention with KI. The
international Basic Safety Standards, to which the U.S. is a signatory,
call for KI to be part of emergency planning. Internationally, the
NRC's penny-pinching on KI is bringing no glory to U.S. radiation
protection efforts. If you talk to doctors and radiation protection
specialists from other countries, they shake their heads in disbelief
that the United States believes it cannot afford the million or two or
three dollars it would take to bring its children's protection up to
world standards. (The international community can also see, from the
frequency with which NRC Commissioners jet around the world, that the
NRC is not completely strapped for funds.)
The issue is not whether evacuation is better than KI. Of course, it is
better to get children and adults out of harm's way, if you can. But as
the rest of the developed world seems to understand, it is better to
have three arrows in your quiver than two. Accidents are by their
nature unpredictable. It is better to have life preservers on your
boat, and a first aid kit in your car, than to count on someone flying
to your aid in a crisis.
How cheap is KI? On the NRC's rulemaking website, you can find an
e-mail from an Ohio state official, forwarding an e-mail from a Swedish
firm that offers KI in quantity at six cents a pill, with a guaranteed
shelf life of ten years.
The only argument against having KI close to reactors that would make
sense, if it were true, is that big accidents will not happen. If only
we knew that! Big accidents are unlikely, to be sure, but complacency
is a dangerous path to follow. If we knew that accidents would never
happen, we could scrap all of emergency planning, including sirens and
drills. Moreover, all the estimates of accident probability deal with
unintended accidents; in today's world, terrorism is a wild card for
which we have no probability estimates.
In 1996, Maine decided to adopt KI stockpiling. A member of the state's
advisory committee on radiation said, "Knowing what we know, ten years
from now, I'd rather say that we erred on the side of caution." 20
years after TMI, it's time for the federal government to show the same
good sense.
For those who read to the bottom of this long message, thanks for your
attention, and I hope you'll consider sending your views to the NRC.
I'm sure that perspectives from other countries would also be valuable.
Peter Crane
pgcrane@erols.com
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