We are vulnerable.

For details on the referenced materials, see the References page

In a report to the United States Senate, the Graham/Talent WMD Commission[1] declared that America is unprepared for a nuclear emergency.

Should an accident or sabotage occur at one of our nation’s nuclear reactors, or America be attacked with a nuclear weapon or a dirty bomb containing common radioactive iodine; the consequences would be devastating.

In 2002, Congress passed the Bioterrorism Act which directed the President to create guidelines for stockpiling and distributing Potassium iodide (KI) for radiation protection.

This Act has been ignored.

An Unnecessary Risk

 I. DENIAL-America Unprepared

KI

Experts agree that most radiation damage in a serious emergency could be prevented by the use of Potassium Iodide (KI), a pharmaceutical that protects the thyroid gland from radioactive iodine (RAI).  The FDA has stated unequivocally that KI prophylaxis can provide “safe and effective protection against thyroid cancer caused by irradiation.“[2] Former Secretary of Health and Human Services, Michael Leavitt, has written “[w]e also agree with the National Academy of Sciences conclusions regarding the need for KI” and declaring that there are no “alternative and more effective”[3] measures than KI tablets. It is a product that it has been used for more than 100 years in pediatric medicine, and its value and safety are well-established.

 

“safe and effective protection against thyroid cancer caused by irradiation.”

 

Millions of Europeans were exposed to RAI following the Chernobyl accident. In Russia and Poland authorities distributed KI from cold-war stockpiles, and individuals who received it were protected. But according to the World Health Organization (WHO), where KI was not available the incidence of thyroid cancer has soared more than 100 times the pre-accident rate. They noted, though, that this could have been “reduced or even prevented by proper implementation of stable iodine prophylaxis.”[4] The US Nuclear Regulatory Commission (NRC) reported that “The Russians were apparently well prepared for large-scale distribution of KI tablets…Thousands of measurements of I-131 [RAI] activity in the thyroids of the exposed population suggest that the observed levels were lower than those that would have been expected had this prophylactic measure not been taken. The use of KI by the Pripyat population in particular was credited with permissible iodine content (less than 30 rad) found in 97% of the 206 evacuees tested at one relocation center. It is also important to note that no serious side effects of KI use have been reported to date.”[5]

 

Congress Acts, but is Overruled 

In 2002, Congress passed the Bioterrorism Act which directed the President to create guidelines for stockpiling and distributing KI.[6] The Act also directed the National Academy of Sciences (NAS) to make recommendations on how best to implement a KI program. The 2004 NAS report called for pre-distribution of KI, the development of national stockpiles, its use in a radiological emergency by anyone at risk of thyroid cancer, and the creation of a national distribution capacity in order to protect the public.[7]

Unfortunately, at the urging of special political interests, the Bush Administration decided to ignore these recommendations.  Although existing emergency response plans recognized that RAI could spread downwind for 50 miles in a serious accident[8], the Administration’s plan was to limit KI stockpiling to just 10 miles around US nuclear reactors[9]. Thus, in a radiation emergency, KI would not be available to most Americans, and if the radiation spreads as predicted, millions could be in danger unless evacuated.  The threat would remain until the radiation slowly dissipated to safe levels, but this could be weeks or more.

But there is no evidence that a mass evacuation is feasible.  Further, there is almost no KI stockpiled nationally in the event of a terrorist act.  Surprisingly, the Obama Administration has continued the Bush KI policy despite warnings from Congress, the medical community, and various emergency response officials.

 

there is no evidence that a mass evacuation is feasible

 

II. THE SCIENCE, NUMBERS, AND EVIDENCE

No Scientific Support for 10 Miles

Health and Human Services Secretary Kathleen Sebelius has written that limiting KI distribution to just 10 miles around nuclear facilities is sufficient to protect the public.[10]  Yet two comprehensive NRC research studies on the effects of severe accidents predict just the opposite.  Both concluded that radiation levels from 25 to 50 miles could be hundreds of times above safe amounts.[11] [12]  Sadly, these predictions were borne out at Chernobyl, with the WHO reporting that “The Chernobyl accident has thus demonstrated that significant doses from radioactive iodine can occur hundreds of kilometers from the site, beyond emergency planning zones”.[13]  This widespread contamination led to thousands of cases of preventable thyroid cancer, mostly among children.

 

“significant doses can occur hundreds of kilometers beyond emergency planning zones”

 

US officials do not dispute this finding. The US NRC has written that “Four years after the accident, an increase in the number of thyroid cancers was detected in Belarus, Russia, and Ukraine…Notably, this increase, seen in areas more than 150 miles (300 km) from the site, continues to this day.”[14] It was further noted that “the vast majority of the thyroid cancers were diagnosed among those living more than 50 km (31 miles) from the site.“[15] While estimates vary as to the actual number of thyroid cancer cases attributable to Chernobyl, the NRC’s own estimate is that 6000 children developed the disease.[16] Estimates by other (non-industry) groups are considerably higher.

Despite this disturbing number, the US nuclear industry continues to oppose expanding KI stockpiles beyond 10 miles, and the opposition to KI stockpiling by HHS Secretary Katherine Sebelius has not changed.  But given the evidence to date; the acknowledgement of the danger; and the warning by the Graham/Talent Commission, her position is difficult to understand.

 

Nuclear Weapons and RAI

The ability of nuclear weapons to spread RAI has been convincingly demonstrated. Thyroid disease from the 1945 Japanese bombings can still be found[17], and a 26-year study has tracked the effects of RAI among South Pacific Islanders dusted by fallout from a 1954 atomic test.  The authors concluded that “The Marshall Islands experience clearly identifies the risk to the thyroid gland from radioactive fallout.“[18] The study found that thyroid damage began appearing after about 9 years, and that “Within the next 3 years, 15 of the 22 Rongelap people [68%] who had been under age 10 years at the time of exposure had developed thyroid lesions.” They further noted that by the third decade after the fallout exposure “most of the Rongelap children and many adults developed thyroid nodules, some of which proved to be malignant. In addition, thyroid atrophy accounted for severe growth retardation in 2 boys.” In 1983, the US government agreed to pay the people of the Marshalls $150 million for medical and radiological monitoring and the payment of claims.

 

“most of the children developed thyroid nodules, some of which proved to be malignant”

 

The spread of RAI from nuclear weapons testing in the US also demonstrated the danger to the thyroid. The National Cancer Institute has calculated that between 11,000 and 200,000 excess cases of thyroid cancer occurred in this country as a result of testing in Nevada.[19]  Cancers were heaviest in the Southwest, and in 1992 the Radiation Exposure Compensation Program was established which, by June 2007, had authorized payments of $1.2 billion.

 

Presidential Commission on Three Mile Island[20]

The Presidential Commission appointed to study the accident at Three Mile Island concluded that the consequences would have been “catastrophic” had the reactor containment building failed, as was widely feared at the time. Their report specifically noted that “The greatest concern during the accident was that significant amounts of radioactive material (especially radioactive iodine) trapped within the plant might be released.” The Commission was especially critical of the fact that although authorities had known of KI’s value for over 25 years, none was available at the time of the accident. As a result, they recommended that “an adequate supply of the radiation protective (thyroid blocking) agent, potassium iodide for human use should be available regionally for distribution to the general population.” This recommendation has been ignored.

 

“an adequate supply should be available”

 

Fukushima and the Threat to Tokyo

In Japan, following the disaster at Fukushima, the level of RAI in drinking water in Tokyo concerned top officials who secretly considered evacuating the city[21] which is 150 miles from the accident site. Though it is too early to measure the impact of Fukushima on the Japanese population, there is a likelihood that substantial thyroid damage will begin appearing in about 5 years.

The NRC responded promptly to the Japanese emergency.  On March 16, 2011, just 5 days after the event, they released a statement[35] noting “the NRC believes it is appropriate for US residents within 50 miles of the Fukushima to evacuate.”  This recommendation was supported by calculations predicting that radiation levels to the thyroid would be nearly 10 times the safe amount at this distance.  Clearly a threat of this magnitude would indicate the need for KI prophylaxis as a supplement to evacuation.

Fortunately, Japanese nuclear officials were able to reduce the amount of radiation released by flushing the Fukushima facility with seawater; thus destroying the reactor. However, the initial fears of contamination out to 50 miles by the Commission’s own safety experts is revealing.  It provides, once again, evidence of the known inadequacy of the 10-mile limitation on KI.

 

Bipartisan Call for KI Stockpile

In May of 2011, a bipartisan “Congressional Letter” signed by 30 US Congressmen and women was sent to President Obama calling for the KI stockpile to be fulfilled. To date, this letter has been ignored.[22] (See the “Congressional Letter” here.)

 

III. CONFIRMATION AMONG LEADING ORGANIZATIONS

 

National Academy of Sciences (NAS)

In a 2004 study[23], the NAS stated: “KI should be available to everyone at risk of significant health consequences from accumulation of radioiodine in the thyroid in the event of a radiological incident.” The report also noted that “KI distribution should be included in the planning for comprehensive radiological incident response programs for nuclear power plants.” Unfortunately, our government has not acted on this recommendation.

 

American Thyroid Association (ATA)

The ATA (supported by the American Association of Clinical Endocrinologists, the Lawson Wilkins Pediatric Endocrine Society, and the Thyroid Foundation of America) released a statement in 2002 endorsing the use of KI in the event of a radiological emergency. It called KI “an essential adjunct to evacuation, sheltering, and avoiding contaminated food, milk, and water.”[24] Nine years later, at the time of Fukushima, the ATA again urged the White House to consider KI, noting that “The need for advance preparation is obvious,” and calling for supplies to be predistributed within 50 miles of US nuclear plants.[25] Unfortunately, no action has been taken.

 

“The need for advance preparation is obvious”

 

American Academy of Pediatrics (AAP)

In their 2003 study involving nuclear disasters and children, the AAP stated “…potassium iodide is of proven value for thyroid protection but must be given before or soon after exposure to radioactive iodine, requiring its placement in homes, schools, and child care centers…”[26]

 

IV. OBJECTIONS AND MISLEADING CLAIMS

 

1. The Rationale for Limiting KI Distribution to Just 10 Miles:

There are four technical reasons given that support the nuclear industry’s decision to refuse to expand KI distribution beyond 10 miles. These are described in the government’s official plan for accident response in the event of a release from a nuclear power plant.[27]

Reasons one and two deal only with “Traditional Design Basis” accidents which are less severe and release only small amounts of radiation that prepared safety systems can contain. In these cases, the danger of cancer is minimal. However, in the event of a non-design basis accident, reason four in the plan expresses hope that actions taken to protect people within ten miles might be expanded beyond this range (though without advance preparation, this is probably not possible).

However, it is the third reason that provides the actual rationale to limit planning to a ten mile emergency zone around nuclear plants. It reads, in its entirety, “For the worst core melt sequences, immediate life threatening doses [of radiation] would generally not occur outside the zone“.

This comforting assurance is misleading. Yes, high “immediate life threatening doses would generally not occur outside the zone,” but high radiation doses do not cause thyroid cancer. They kill before cancer has time to develop. Cancer-causing doses, while seldom fatal, are much smaller, but (as the 6000 cases from Chernobyl proved) these can occur over a very large area, threatening millions. Our government, however, deals with the cancer threat by ignoring it.  The current plan would effectively deny KI to all but a few children within the emergency zone, but everyone else would be left at risk.

Industry planners, of course, know this. Despite their repeated assurances of the adequacy of 10 miles for KI distribution, their plan quietly makes the admission that in a severe release “protective actions would need to be taken outside the planning zones“[28] Yet these same planners have made virtually no plans to prepare for this contingency.  This is not a small flaw.

 

2. KI “Only Protects the Thyroid”:

The most common charge leveled against KI is that it is only marginally useful because it “only protects the thyroid.” For example, the NRC has stated that KI “can help to reduce the risk from thyroid disease, including cancer as a result of a severe reactor accident [but] KI doesn’t protect the thyroid gland from any other radioactive element nor does it protect the thyroid or the whole body from external exposure to radiation. Its use is very limited.“[29]

Calling KI use “very limited” is disingenuous.  Our government is certainly aware that NRC research, plus the Japan, Marshall Islands, and Chernobyl experiences all demonstrate that the primary need in an accident is for thyroid protection, and that other threats are difficult to find or identify. In fact, the NRC has published their finding that ten years after Chernobyl, “except for thyroid cancer, there has been no confirmed increase in the rates of other cancers, including leukemia, among the first responders, liquidators, or the public that have been attributed to releases from the accident. In addition, there is no evidence of any excess hereditary diseases in children born after the accident.“[30]

For the nuclear industry to minimize KI because “it only protects the thyroid” while acknowledging that thyroid damage is (by far) the most prevalent consequence of an accident, is to bend logic in order to support an otherwise unsupportable position.

 

3. Evacuation and Food Interdiction

In 2005, following the release of the National Academy of Sciences endorsement of KI, a senior NRC official wrote to the Department of Health and Human Services arguing that rather than stockpile KI, “other, more effective, protective measures are in place to protect the thyroid…and that expanded distribution of KI is unnecessary.”[31] These “other, more effective, measures” referred to were evacuation and blocking all food and water in a 50 mile “ingestion zone” around a power plant where officials recognized the possibility of RAI contamination.

But there is little confidence that this program could work and then HHS Secretary, Michael Leavett, correctly rejected this claim. Food control and large evacuations–though theoretically effective if successful–are unproven and the practical difficulties in doing them are enormous. The area that might be threatened could be thousands of square miles and contain millions of people.  Most major US cities could potentially be affected.  Further, how to supply food and water to those who evacuate, or replace these for the those who do not evacuate, has not been explained.

Worse, though, merely blocking contaminated food and water is not a fully effective solution. Research on the dispersion and effects of radiation clearly shows that during the most dangerous stage of a release “the thyroid dose [of radiation] is dominated by the inhalation of radioiodine” and “protective measure[s] must reduce the inhalation dose.”[32] Therefore, even if efforts to block ingestion of contaminated food were successful, this would not prevent an inhalation hazard during the time that RAI is most dangerous.

Nevertheless, the January, 2008 carefully worded statement from the White House[33] ignored the difficulties of evacuation or food interdiction, and concluded that KI tablets “offer negligible additional protection” to the public if efforts to control food and evacuate everyone are successful. Yes; anyone evacuated out of the danger area would have no need for the additional protection of KI, but the basis for believing this optimistic assumption is clearly lacking.

 

4. The Milk Pathway

The nuclear industry argues that any injuries beyond 10 miles (especially among children) would be caused by drinking milk which has been contaminated by RAI. Their scenario is that the RAI would drift airborne throughout the 50 mile “ingestion zone” around a damaged reactor and eventually settle out onto grass in pastures. The grass would be eaten by cows, and the RAI would enter their milk, which will be drunk by children, and this will cause thyroid cancer. Therefore, one need merely to interdict milk from contaminated areas, and the children will be safe. KI tablets would be “unnecessary.”

This overly simplistic approach, however, fails even the most basic analysis.

The call for restrictions on milk is an acknowledgement that airborne radiation represents a danger out to 50 miles.  But if RAI can settle-out onto pastures, it can settle-out everywhere. Thousands of square miles of non-pasture could be contaminated, and the predicted radiation levels could reach hundreds of rads.[34] However, the NRC’s “Protective Action Guidelines” call for protective actions if radiation levels reach just 2 to 5 rads.[35] Therefore, children within 50 miles could be subject to exposure to RAI at dangerous levels from dust kicked up by the wind, or from cars travelling on roads coated with RAI, or from any of a thousand other sources. It would be impossible to avoid, regardless of how carefully one watches a child’s diet, and it would be unacceptably dangerous for any child in that area to be left unprotected. One can only wonder how threatened parents will respond upon learning that only some children (but not theirs) are receiving protective KI tablets.

if RAI can settle-out onto pastures, it can settle-out everywhere

The basis behind the argument that drinking milk was the cause of most of Chernobyl’s cancers is questionable.  In 1999, 13 years after the accident, scientists at the NRC addressed the question of the source of the radio-iodine contamination among children.  They reported that the relative contributions from “ingestion” (drinking milk) versus “inhalation” (breathing) could not be assessed because air-sampling had not been conducted early in the accident.  But inhalation, they concluded, “was most likely a major source of the dose in some areas near the plant.”  Some years later, however, though no new air-sampling data was available, the industry reversed its earlier conclusion and settled on the position that ingestion of milk was the primary pathway.

Although efforts to control radioactive milk and other foods are certainly steps to take whenever possible, they are far from sufficient. Only enough KI for everyone could be a feasible counter-measure, and the failure to have enough KI could have severe consequences.

 

5. The Effect on the Nuclear Industry

Various statements made by officials indicate that the nuclear industry is concerned that wide distribution of KI would send an implicit message that could undermine the public’s confidence in their reactors.[36] While this concern may or may not be realistic, it is an insufficient reason to deny the benefits of KI to the American public. The first responsibility of public officials is to protect the public; not the reputation of the nuclear industry. Further, steps are available to minimize the possibility of negative publicity through controlled storage of the tablets in secure locations such as police or fire stations, post offices, or schools.

 

KI is easy to stockpile and distribute.  The tablets are small, lightweight, very long lasting, and require no special storage requirements. Under one format, 9000 tablets could be stored in a carton about the size of a microwave oven. The tablets have a long shelf life and will last for years or even decades. Importantly, in case of an emergency, the distribution of these small white pills would help to assure a nervous public that officials have the tools, ability, and forethought necessary to protect them.

 

V. IN THEIR OWN WORDS

 

Despite government policies which downplay the value of KI, the NRC’s “Frequently Asked Questions About Potassium Iodide” paints a very different picture.[37] This website notes the following:

 

1. Why KI

“Administering KI can be a reasonable, prudent, and inexpensive supplement to in-place sheltering and evacuation.”…It can “reduce the risk of thyroid cancers and other diseases that might otherwise be caused by exposure to radioactive iodine that could be dispersed in a severe nuclear accident.”

 

2. KI Works

KI “will effectively saturate the thyroid gland in such a way that inhaled or ingested radioactive iodines will not be accumulated in the thyroid gland. The risk of thyroid effects is reduced. Any radioactive iodine taken into the body after consumption of KI will be rapidly removed.”

putting public relations over public health

 

3. The Suitability for Stockpiling

Potassium iodide tablets are inherently stable and do not lose their effectiveness over time…studies over many years have confirmed that none of the components of KI tablets, including the active ingredient, has any significant potential for chemical degradation.”

 

VI. COST

KI costs pennies. A single tablet costs about a quarter and the manufacturer will guarantee that it will last for 10 years or longer. Thus, the annual cost is 2.5 cents ($0.025) for adults, and half of this for children (who can take half a tablet). A stockpile for the nation’s 100 million children and young adults living within 50 miles of a nuclear power plant would cost $9M a year for 10 years, and would be cost free for an indeterminate number of years after that.

Perhaps most surprising is that Congress need not appropriate additional money to implement a national KI program.  Under “Project BioShield”  which was passed and signed by the President in 2004, over $5 billion was set aside to develop and implement medical countermeasures to protect America in the event of a nuclear, biological, radiological, or chemical attack.  To date, most of this money has not been spent because very few programs that have been considered meet the program’s criteria.  KI, however, clearly qualifies.

Thus, despite acknowledging that KI is prudent, effective, long-lasting, inexpensive, and already paid for, the nuclear industry continues to oppose national stockpiling.

 

The decision to choose to remain unprepared is baffling

 

VII. CONCLUSION

On May 31, 2011, the Chairman of the Nuclear Regulatory Commission, Gregory Jaczko, issued a statement[38] regarding the NRC’s commitment to safety in light of the events that had recently taken place at the Fukushima nuclear site in Japan. Dr. Jaczko’s statement noted that while he was visiting Japan during the accident, he received and approved a confidential recommendation from the NRC’s senior staff that “we needed to advise American citizens to stay 50 miles away from the troubled nuclear site.” He noted that this recommendation “did not focus on what might be popular with the nuclear industry but instead recommended action in the best interest of safety.”

Dr. Jaczko was correct that his statement was not popular with the nuclear industry, and its controversy may have been a factor in the decision made a few months later that led him to leave the NRC. But the potential radiation danger to Americans in Japan was a threat that Dr. Jaczko could not ignore, and he chose to make safety his primary concern.

 

what was true in Japan is also true in America

 

Dr. Jaczko’s call for Americans to stay 50 miles away from the stricken reactors indicated his understanding that protective measures in a severe accident cannot be limited to just ten miles around a release. Radiation can, and will, travel well beyond this artificial boundary. But if this was true in Japan, it is also true in America, and officials should not allow our country to remain unprotected for reasons which fail to meet the standards that the evidence demands.

It should be noted that the stated and approved policy of the NRC is that efforts to insure nuclear safety must be treated “as a matter of prudence rather than necessity” [39] In other words, where reasonable, the American public should expect officials to act on the side of caution. This is the “Safety First’ culture that the NRC deservedly prides itself on and generally achieves. But this is not how the nuclear industry treats the matter of potassium iodide. Limiting supplies of KI means limiting safety. This decision was made despite demonstrated evidence and the recommendations of experts, and it represents a risk to the public that has no corresponding benefit. The stark fact is that more than 30 years after the Three Mile Island recommendations; despite the events at Chernobyl and Fukushima; regardless of the NRC’s operative policy of “prudence rather than necessity”; and in spite of the findings of the National Academy of Science and the Graham/Talent Commission, there is still no adequate supply of this safe, effective and inexpensive product KI in the US today.

 

Will it take nothing less than a disaster to change this?

 

Anbex
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