Please sign onto the FUSE letter supporting the continued distribution of KI within 20 miles of a nuclear facilitiy.
To sign on please email me you name and address. Thanks.
Susan Shapiro
FUSE USA
21 Perlman Drive
Spring Valley, NY 10977
(845) 371-2100
Dr. John Marburger, III
Director, Office of Science and Technology Policy
Executive Office of the President
New Executive Office Bldg.,
Washington D.C. 20502
Fax 202-456-6021
Attn: Dawn at depperson@ostp.eop.gov
November 1, 2007
RE: Bioterroism Act Section 127- Stockpiling Potassium Iodine (KI) for residents living 20 miles from a nuclear reactor site.
Dear Dr. Marburger:
The following comments are submitted on behalf of FUSE USA, state and local public interest groups, and individuals living within 20 miles of the Indian Point reactors that are leaking tritium, strontium 90 and cesium 137 into the environment urging implementation of the Bioterrorism Act's Section 127 - stockpiling Potassium Iodine (KI) for residents living 20 miles from a nuclear reactor site.
Because NEI (Nuclear Energy Institute) has lobbied that distribution of KI causes PR problems for the industry during their push for a Nuclear Renaissance, the nuclear industry, the Nuclear Regulatory Commission and the Administration are wrongfully attempting to block the pre-distribution of Potassium Iodide (KI) in the 20 mile radius surrounding a reactor site.
FUSE USA, and the below co-signer, s herein implore you to place the public's interest, human health and safety first in this important matter and support the implementation of the Bioterrorism Act's Section 127.
We understand and deeply regret that President Bush has cold heartedly moved to nullify Section 127 of the 2002 Bioterrorism Act law that would greatly improve protection for the public in case of nuclear Terrorism or in the case of a significant fast moving event at aging plants like Entergy's Indian Point. The Nuclear Regulatory Commission and the nuclear power industry fought the legislation; however it passed almost unanimously and was signed into law by a Pro-Nuclear president. The White House hailed the result, declaring that henceforth, this "crucial" drug would be available where and when needed in a a fast moving emergency.
More than five years after the law's passage the broader distribution of KI has yet to take place due to the NRC's foot dragging maneuvers that are being driven by heavy lobbying from NEI and reactor owners. By doing this the nuclear industry is not adequately protecting our children and our families, and placing reactor communities at risk should a terrorist attack or radiological event occur at the Indian Point Nuclear reactors located just 24 miles up the Hudson River from Manhattan.
The Department of Health and Human Services, who had initial authority over the statute, tried to make the bill a reality; however, it has been frustrated by the NRC, working behind the scenes with the White House staff who view the distribution of K1 an inconvenient truth at a time when they were/are trying to force a Nuclear Renaissance on America and are engaged in unprecedented Propaganda campaign. Please note that the NRC Staff involved in this unethical blocking of K1 distribution are not medical doctors.
The Department of Health and Human Services (HHS), has found that “the effectiveness of KI as a specific blocker of thyroid radioiodine uptake is well established (Il'in LA, et al., 1972) as are the doses necessary for blocking uptake. As such, it is reasonable to conclude that KI will likewise be effective in reducing the risk of thyroid cancer in individuals or populations at risk for inhalation or ingestion of radionuclides”.
The NRC's argument against the guidelines are based on a provision of the statute that permits the President to forgo expanded KI stockpiling if he identifies a more effective alternative means of thyroid protection. It is noted here that the President has not offered up a viable workable alternative for thyroid protection.
KI is recommended to prevent thyroid cancer in the event of a radiological incident by: U.S. Food and Drug Administration; World Health Organization; American Thyroid Association; American Academy of Pediatrics; International Agency Atomic Scientists; National Academy of Sciences; National Council on Radiation Protection; Federation of American Physics; Physicians for Social Responsibility; Union of Concerned Scientists; and locally for example the Massachusetts Medical Society (MMS) July 22, 2002 adopted a policy which calls for providing thyroid-blocking agents to all Massachusetts communities for protection against radioiodine. Further we know that nations around the world have routinely stockpiled potassium iodide for many years
Placing public health and safety at risk to support the Nuclear Industry, is unconscionable. Especially since the costs of KI is minimal, the tablets are only pennies. Whereas, thyroid cancer surgery and cures cost hundred of thousands of dollars and the loss of human life.
President Bush has signed an order stripping HHS of its responsibilities for KI under the law and transferring said responsibility to an under-staffed and overworked
There is a need to stockpile KI beyond 10-miles, as appreciated by Congress and by NRC in their own studies:.
1. Federal studies indicate that the consequences of an accident can spread well beyond 10-miles. Calculation of Reactor Accident Consequences U.S. Nuclear Power Plants (CRAC-II), Sandia National Laboratory, 1982 states: The consequences of a core melt at Pilgrim NPS, for example, would result in a 20 miles peak 1st year fatal radius; a 65 miles peak 1st year injury radius; and 23,000 peak cancer deaths. These estimates are conservative.
2. NRC's site specific consequence plume models are inaccurate because they use a steady- state straight-line Gaussian plume distribution model when instead variable trajectory models are needed due to the complexity of winds at reactor sites resulting from the sea-breeze or lake effect and wind variability resulting from hills, river valleys, and building clusters. Use of the appropriate variable trajectory models would demonstrate that plumes and consequences extend further than currently projected, thereby justifying KI distribution beyond 10 miles.
3. The reason to provide KI in the 10-20 mile zone is because of the possibility of inhalation during an accident of significant consequence. For example, Dr. Temeck (FDA representative to NRC's KI Core Group Meeting, Tempe Arizona, March 4, 1999) stated that exposure to children after Chernobyl resulted from “a combination of inhalation and ingestion.”
4. NRC's NUREG-1633 points out that radioactive iodide can travel hundreds of miles on the winds. An increase in cancer caused by Chernobyl was detected in Belarus, Russia and Ukraine. Notably, this increase, seen in areas more that 150 miles from the site, continues to this day and primarily affects children who were 0-14 years old at the time of the accident. The vast majority of the thyroid cancers were diagnosed among those living more than 31 miles from the site. The 2001 figures showed 11,000 thyroid cancers at 31 miles.
Despite the above studies, for decades The NRC has opposed the enactment of Section 127; NRC staff consistently has opposed stockpiling potassium iodide and has provided misinformation to other Government agencies regarding KI.
Therefore, the Congress in the Bioterrorism Act directed authority to the National Academy of Sciences and to HHS for assessment and implementation
On November 1, 2005, William F. Kane, Deputy Executive Director for Reactor and Preparedness Programs, sent a letter to Dr. Robert Claypool of the Department of Health and Human Service, which seriously distorted the findings of the report on KI issued in 2004 by the National Research Council of the National Academies of Science (NAS). The NRC letter quoted one sentence from the NAS report, from page 159, while omitting the four preceding sentences to “raise questions regarding the usefulness of expanded distribution of KI," as the NRC letter claims.
However, the NAS reported clearly states that,
"In the event of nuclear accidents or as a result of nuclear terrorism, radioiodine could be released to the environment. Because iodine concentrates in the thyroid gland, exposure to radioiodine by inhalation of contaminated air or ingestion of contaminated milk and other foods can lead to radiation injury to the thyroid, including risk of thyroid cancer and
other thyroid diseases. Thyroid radiation exposure from radioiodine can be limited by taking stable iodine. KI is a chemical compound that contains iodine and can be used to protect the thyroid gland from possible radiation injury by reducing the amount of radioiodine concentrated by the thyroid after inhalation of radioiodine. KI is also effective for protection against the harmful thyroid effects of radioiodine ingested in contaminated milk and other food, but food testing and interdiction programs in place throughout the United States are more effective preventive strategies for ingestion pathways."
The NAS report made clear that depending on site-specific factors, KI might be desirable beyond the 10-mile EPZ, since the 10-mile radius does not necessarily correspond to the actual risk presented. See Recommendation 2, from p. 160, of the section on "Benefits of and Risks Posed by Potassium Iodide Distribution":
"KI distribution should be included in the planning for comprehensive radiological incident response programs for nuclear power plants. KI distribution programs should consider pre-distribution, local stockpiling outside the emergency planning zone (EPZ), and national stockpiles and distribution capacity." [Boldface in the original.]
In the summer of 1998, NRC Commissioners, after authorizing publication of "NUREG-1633," a staff analysis of KI, ordered it withdrawn from circulation after scathing comments from state health officials alerted the Commissioners to its numerous misstatements and distortions. This NRC document, 40 pages long, managed not to mention the FDA's finding that KI was "safe and effective."
A member of NRC staff has been quoted as saying, “distribution of the pills does NOT LOOK GOOD FOR THE INDUSTRY.” It is unacceptable for public health decisions to based on a Nuclear Renaissance Propaganda Campaign.
One of the key lessons learned from Katrina is that we as a nation must be prepared and have a plan already in place to protect human health, public safety, and the environment. The government's dismal response to Hurricane Katrina has become a major embarrassment to the Administration, and a tragedy for American citizens.
Accidents can happen due to mechanical failure, human error or acts of malice, and that the government's response may not be adequate or timely. The reactor communities living within 20 miles of America's fleet of 104 aging nuclear reactors with known safety issues, and aging problems, such as reactor vessel thermal shock and risk of pipe burst caused by Flow Accelerated Corrosion (FAC), must be adequately protected by proactively distributing KI to reactor communities within 20 miles of nuclear facilities. It is imperative that the recommendation of health experts are followed.
In a nuclear accident or terrorist attack, radioactive iodine will be released; will be absorbed by the human thyroid; and in sufficient quantity will cause thyroid cancer, thyroid disease and/or growth disorders in those exposed-especially the unborn and children, our most important and vulnerable citizens. This risk can be mitigated or prevented by taking a potassium iodide tablet - an over-the-counter FDA approved and
recommended substance - before or shortly after exposure. Because it is time dependent, KI must be proactively, stockpiled in reactor communities, so it will be available, if and when needed.
FUSE USA implores you, Dr. Marburger, to please stop President Bush from flip-flop on this issue which is so important to the public health and safety of millions of Americans living within the EPZ for American's 104 nuclear reactors.
We beseech you to impress on President Bush how important it is that he continue to support distribution of KI to 20 miles surrounding nuclear facilities; following the mandate of the 2002 Congress, and advice of America's top scientists, medical professionals in order to protect American public health and safety.
Respectfully,
Susan Shapiro
FUSE USA, President
21 Perlman Drive
Spring Valley, NY 10977
Sherwood Martinelli
FUSE USA, Vice President
351 Dyckman Street
Peekskill, New York 10566
Maureen Ritter
36 Campbell Ave.
Suffern, NY 10901
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